Initial Statement of Reasons 

Proposed Amendments to the 

California Regulation for Reducing Emissions from 

Consumer Products 

and 

Test Method 310: Determination of Volatile Organic

Compounds in Consumer Products and Reactive Organic

Compounds in Aerosol Coating Products 

Release Date: September 29, 2010 

State of California 

AIR RESOURCES BOARD

Initial Statement of Reasons 

Proposed Amendments to the 

California Regulation for Reducing Emissions from 

Consumer Products 

and 

Test Method 310: “Determination of Volatile Organic Compounds 

in Consumer Products and Reactive Organic Compounds in 

Aerosol Coating Products” 

To be considered by the Air Resources Board at a 

Public Hearing on November 18, 2010, at: 

Byron Sher Auditorium 

Air Resources Board, Cal/EPA Headquarters 

1001 I Street 

Sacramento, CA 95814 

P.O. Box 2815 

Sacramento, CA 95812 

September 29, 2010

This report has been prepared by staff of the California Air Resources Board. 

Publication does not signify that the contents reflect the views and policies of the 

Air Resources Board. The mention or representation of trade names or commercial 

products does not constitute an endorsement or recommendation for use. 
Reviewed by: 

Carla D. Takemoto, Manager, Technical Evaluation Section 

David Mallory, Manager, Measures Development Section 

Judy Yee, Manager, Implementation Section 

Janette M. Brooks, Chief, Air Quality Measures Branch 

Cynthia Marvin, Assistant Chief, Stationary Source Division 

Richard W. Corey, Chief, Stationary Source Division

Developed by: 

Nicholas Berger (Lead) 

Robert Barrera 

Margaret Chu 

Tim Dunn 

Terri Edwards 

Lori Gilbert 

Russell Grace 

Robert Jenne 

Trish Johnson 

Jenifer Kiger 

Reza Mahdavi 

Irina Malkina 

Jasmine Nguyen 

Olufemi Olaluwoye 

Michael Orbanosky 

Ravi Ramalingam 

Maryana Visina 

Barbara Zavala 
Table of Contents - 1 

Table of Contents

Executive Summary .................................................................................................... 1

A. Authority to Regulate Consumer Products........................................................ 2

B. Existing Regulations ......................................................................................... 2

C. Regulatory Development Process..................................................................... 2

D. Basis for the Proposal and VOC Emissions...................................................... 3

E. Consumer Product VOC Emission Reduction Commitments in the State 

Implementation Plan (SIP) ................................................................................ 4

F. Summary of Proposed Amendments to the Consumer Products Regulation.... 4

1. Definitions (section 94508)................................................................................ 5

2. Proposed Amendments to Standards for Consumer Products (section 94509) 5

3. Proposed Amendments to Administrative Requirements (section 94512) ........ 9

G. Proposed Amendments to Test Method 310..................................................... 9

H. Compliance with the Proposed Amendments ................................................. 10

I. Economic Impacts........................................................................................... 12

1. Overall Cost .................................................................................................... 12

2. Cost-effectiveness .......................................................................................... 12

3. Return on Owner’s Equity (ROE).................................................................... 12

4. Impacts on California Businesses................................................................... 13

5. Increased Cost to Consumers......................................................................... 13

6. Fiscal Impacts................................................................................................. 13

J. Environmental Impacts ................................................................................... 13

1. Prohibition on Use of Certain Toxic Air Contaminants .................................... 14

2. Limit on Use of Global Warming Compounds ................................................. 14

3. Prohibition on Use of Alkylphenol Ethoxylate Surfactants............................... 15

K. Environmental Justice..................................................................................... 15

L. Future Plans.................................................................................................... 15

M. Recommendation............................................................................................ 16

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

A. Enabling Legislation.......................................................................................... 2

1. Health and Safety Code section 41712............................................................. 2

2. Health and Safety Code section 38500 et seq.................................................. 2

3. Public Resources Code section 21000 et seq................................................... 3

B. Background....................................................................................................... 3

1. Existing Consumer Product Regulations........................................................... 3

2. Consumer Products and the State Strategy for California’s 2007 State 

Implementation Plan (SIP) ................................................................................ 4

3. Consumer Products and the California Global Warming Solutions Act of 

2006 (AB 32)..................................................................................................... 4

4. National Consumer Products Regulations ........................................................ 5
Table of Contents - 2 

Chapter II. Public Process ..................................................................................... 7

Chapter III. Statutory Requirements and the State Implementation Plan 

Commitment for Emission Reductions ............................................ 11

A. VOC Reductions ............................................................................................. 11

B. Greenhouse Gas Reductions.......................................................................... 12

C. Interpretation of the Terms Technological and Commercial Feasibility in 

Relation to Proposing VOC Limits................................................................... 12

1. Technologically Feasible................................................................................. 12

2. Commercially Feasible.................................................................................... 13

D. State Implementation Plans ............................................................................ 14

1. The 2007 SIP Commitment for Consumer Products....................................... 14

2. Future SIPs..................................................................................................... 16

Chapter IV. Air Pollutants, Area Designations, and Consumer Products’ 

Emissions ........................................................................................... 17

A. Criteria Pollutants............................................................................................ 17

1. Ozone ............................................................................................................. 17

2. Fine Particulate Matter.................................................................................... 19

B. Ambient Air Quality Standards........................................................................ 20

1. Area Designations for California Ambient Air Ozone Standard....................... 21

2. Area Designations for California Ambient Air PM2.5 Standard......................... 21

C. Climate Change .............................................................................................. 23

D. Consumer Product Emissions......................................................................... 24

1. VOC Emissions............................................................................................... 24

2. Greenhouse Gas Emissions ........................................................................... 25

Chapter V. Development of the Proposed VOC Limits ...................................... 33

A. Surveys, Estimated Emissions, and Reductions from Categories Proposed to 

be Regulated................................................................................................... 33

1. Consumer and Commercial Products Surveys ............................................... 33

2. Staff Evaluation of Emission Reduction Opportunities.................................... 34

3. VOC Emissions, Proposed Categories, and Limits......................................... 34

4. Greenhouse Gas Emissions ........................................................................... 36

B. Commercial and Technological Feasibility of the Proposed VOC Limits......... 36

C. Options for Complying with the Proposed VOC Limits.................................... 36

D. Necessity of Proposed Amendments.............................................................. 39

E. Alternatives Considered.................................................................................. 40

Chapter VI. Plain Language Description of the Proposed Amendments to the 

Consumer Products Regulation ....................................................... 43

A. Proposed Amendments to Section 94508(a): Definitions............................... 44
Table of Contents - 3 

B. Proposed Amendments to Section 94509: Standards for Consumer 

Products.......................................................................................................... 46

1. Proposed Amendments to Section 94509(a) - Table of Standards................. 47

2. Proposed Modifications to Subsections 94509 (i)(3), (m), (n), (o), (p), (q), 

(r), (t), and (u).................................................................................................. 49

C. Proposed Amendments to Sections 94510: Exemptions and Section 94515: 

Test Methods .................................................................................................. 52

D. Proposed Amendments to Section 94512: Administrative Requirements ...... 52

E. Proposed Amendments to Method 310........................................................... 52

Chapter VII. Description of Product Categories ................................................... 57

A. Flying Bug Insecticide (aerosol)...................................................................... 57

B. Furniture Maintenance Product (aerosol)........................................................ 61

C. General Purpose Cleaner (nonaerosol) .......................................................... 63

D. General Purpose Degreaser (nonaerosol) ...................................................... 68

E. Glass Cleaner (nonaerosol) ............................................................................ 73

F. Heavy-duty Hand Cleaner or Soap (nonaerosol) ............................................ 77

G. Metal Polish or Cleanser................................................................................. 82

H. Oven or Grill Cleaner ...................................................................................... 86

I. Special-purpose Lubricant .............................................................................. 91

J. Spot Remover (Dry Clean Only) ..................................................................... 94

K. Wasp or Hornet Insecticide (aerosol)............................................................ 101

Chapter VIII. Economic Impacts............................................................................ 109

A. Summary of Economic Impacts .................................................................... 109

B. Costs of Compliance..................................................................................... 111

1. Recurring Costs ............................................................................................ 111

2. Nonrecurring Costs ....................................................................................... 112

3. Total Costs.................................................................................................... 117

4. Cost per Unit................................................................................................. 119

5. Cost-effectiveness (CE) ................................................................................ 123

C. Return on Owners’ Equity ............................................................................. 124

1. Affected Businesses ..................................................................................... 124

2. Analysis Approach ........................................................................................ 124

3. Assumptions ................................................................................................. 125

4. Results.......................................................................................................... 125

D. Impacts on California Businesses, Consumers, and State and Local 

Agencies ....................................................................................................... 126

1. Potential Impact on California Businesses.................................................... 126

2. Potential Impact on Business Creation, Elimination or Expansion................ 127

3. Potential Impact on Business Competitiveness ............................................ 127

4. Potential Impact on California Employment .................................................. 127

5. Impacts on California Consumers................................................................. 128

6. Potential Impacts to California State or Local Agencies................................ 129
Table of Contents - 4 

E. Other Possible Economic Impacts of Regulatory Changes .............................. 129

F. Mitigation of Potential Impacts Through Additional Regulatory Flexibility......... 129

Chapter IX. Environmental Impacts.................................................................... 133

A. Legal Requirements Applicable to the Analysis ............................................ 133

B. Summary of Proposed Amendments ............................................................ 134

C. Summary of Impacts on Atmospheric Processes.......................................... 135

1. Impacts of Proposed Amendments on Ground-level Ozone 

Concentrations.............................................................................................. 135

2. Impacts of Proposed Amendments on Particulate Matter (Secondary 

Organic Aerosols) ......................................................................................... 138

3. Impacts of Proposed Amendments on Climate Change ............................... 140

4. Impacts of Proposed Amendments on Stratospheric Ozone Depletion ........ 142

D. Other Potential Environmental Impacts......................................................... 144

1. Impacts of Proposed Amendments on Solid Waste Disposal ....................... 144

2. Impacts of Proposed Amendments on Water Quality ................................... 146

3. Impacts of Proposed Amendments on Energy.............................................. 147

E. Analysis of Need for Reasonably Foreseeable Mitigation Measures ............ 149

1. Proposed Mitigation Measure to Prohibit Use of Certain Chlorinated TACs . 149

2. Proposed Mitigation Measure Related to Greenhouse Gas Emissions......... 150

3. Proposed Mitigation Measure Related to Use of Alkylphenol Ethoxylates .... 151

F. Risk Assessment for Implementing the Proposed Amendments................... 152

G. Alternative Means of Compliance ................................................................. 153

H. Environmental Justice................................................................................... 153

Chapter X. Future and Ongoing Activities ........................................................ 157

 A. Consumer Product Emissions Reduction Commitments in the State 

Implementation Plan (SIP) ............................................................................ 157

B. Consumer and Commercial Products Survey ............................................... 158

C. Compliance Assistance................................................................................. 158

List of Tables

Table ES-1 Consumer Product SIP Commitment and Progress to Date................. 4

Table ES-2 Proposed VOC Limits by Product Form, Emissions, and Reductions at 

Effective Date ....................................................................................... 7

Table ES-3 Summary of Complying Products and Complying Market Shares ...... 10

Table III-1 Consumer Product SIP Commitment and Progress to Date............... 15

Table IV-1 Ambient Air Quality Standards for Ozone, PM10 and PM2.5................. 21

Table V-1 Proposed VOC Limits, Emissions, and Reductions at Effective Date. 35

Table V-2 Summary of Complying Products and Complying Market Shares ...... 37

Table VI-1 Proposed New and Modified Definitions............................................. 44
Table of Contents - 5 

Table VI-2 Proposed VOC Limits by Product Form and Effective Dates.............. 48

Table VII-1 Flying Bug Insecticide......................................................................... 58

Table VII-2 Flying Bug Insecticide Proposal ......................................................... 60

Table VII-3 Furniture Maintenance Product .......................................................... 61

Table VII-4 Furniture Maintenance Product Proposal ........................................... 62

Table VII-5 General Purpose Cleaner................................................................... 64

Table VII-6 General Purpose Cleaner Proposal.................................................... 66

Table VII-7 General Purpose Degreaser............................................................... 70

Table VII-8 General Purpose Degreaser Proposal................................................ 73

Table VII-9 Glass Cleaner..................................................................................... 74

Table VII-10 Glass Cleaner Proposal...................................................................... 76

Table VII-11 Heavy-duty Hand Cleaner or Soap..................................................... 77

Table VII-12 Heavy-duty Hand Cleaner or Soap Proposal...................................... 79

Table VII-13 Metal Polish or Cleanser .................................................................... 83

Table VII-14 Metal Polish or Cleanser Proposal ..................................................... 85

Table VII-15 Oven or Grill Cleaner.......................................................................... 88

Table VII-16 Oven or Grill Cleaner Proposal........................................................... 90

Table VII-17 Special-purpose Lubricant.................................................................. 91

Table VII-18 Special-purpose Lubricant Proposal................................................... 93

Table VII-19 Spot Remover (Dry Clean Only)......................................................... 97

Table VII-20 Spot Remover (Dry Clean Only) Proposal.......................................... 99

Table VII-21 Wasp or Hornet Insecticide .............................................................. 101

Table VII-22 Wasp or Hornet Insecticide Proposal ............................................... 104

Table VIII-1a Estimated Change in Formula Cost per Unit .................................... 113

Table VIII-1b Total Estimated Recurring Cost........................................................ 114

Table VIII-2 Estimated Nonrecurring per Product Costs to Comply with the 

Proposed Limits................................................................................ 116

Table VIII-3 Estimated Total Nonrecurring Cost per Category............................. 118

Table VIII-4 Estimated Total Costs to Comply with the Proposed VOC Limits..... 120

Table VIII-5a Estimated Per-Unit Cost Increases from Annualized Nonrecurring ....... 

and Annual Recurring Costs............................................................. 121

Table VIII-5b Sum of Estimated Per-Unit Cost Increases from Both Annualized 

Nonrecurring and Annual Recurring Costs....................................... 122

Table VIII-6 Comparison of Cost-Effectiveness for ARB Consumer Product 

Regulations/Measures...................................................................... 123

Table VIII-7 Summary of Decline in Return on Owners’ Equity (ROE)................. 126

Table VIII-8 California Employment and Payroll in Affected Industries ................ 128

Table IX-1 Proposed VOC Limits, Emissions, and Reductions at Effective ......

 Date.................................................................................................. 136

Table X-1 Consumer Product VOC Reductions Accredited Toward SIP 

Commitment ..................................................................................... 157
Table of Contents - 6 

List of Figures

Figure IV-1 Number of Days the State Eight Hour Ozone Standard was Exceeded 

in Each Air Basin During 2007............................................................ 18

Figure IV-2 Area Designations for State Ambient Air Quality Standard for ........

 Ozone................................................................................................. 22

Figure IV-3 Area Designations for State Ambient Air Quality Standard for PM2.5.. 23

Figure IV-4 Consumer Products VOC Emission Trends ....................................... 26

List of Appendices

Appendix A Proposed Amendments to the Regulation for Reducing Emissions from 

Consumer Products 

Appendix B Proposed Amendments to Method 310: “Determination of Volatile Organic 

Compounds in Consumer Products and Reactive Organic Compounds in 

Aerosol Coating Products” 

Appendix C Summary of Consumer Product Regulatory Actions 

Appendix D Recurring Cost Estimates 

Appendix E Nonrecurring Cost Estimates 
State of California 

AIR RESOURCES BOARD

Initial Statement of Reasons for Proposed Amendments to the 

California Regulation for Reducing Emissions from 

Consumer Products 

and 

Test Method 310: “Determination of Volatile Organic Compounds in 

Consumer Products and Reactive Organic Compounds in 

Aerosol Coating Products” 

Executive Summary 

Executive Summary - 1 

Executive Summary

In this rulemaking, California Air Resources Board (ARB or Board) staff is proposing 

amendments to the Regulation for Reducing Emissions from Consumer Products 

(Consumer Products Regulation). The amendments are primarily designed to reduce 

volatile organic compound (VOC) emissions. The proposed amendments would set 

new or lower VOC limits for 11 categories of consumer products. When fully 

implemented, about 6.7 tons per day of VOC emission reductions would be achieved 

and be creditable to the current State Implementation Plan (SIP) commitment. These 

reductions are an incremental step toward attaining the national ambient air quality 

standard for ozone. Additional reductions would be achieved and creditable toward 

future SIP commitments. 

We are also proposing to prohibit the use of several chlorinated Toxic Air Contaminants 

(TAC) in three categories, preclude use of compounds with higher global warming 

potential (GWP) values in six categories, and prohibit use of alkylphenol ethoxylate 

surfactants in five categories. These proposals are mitigation measures developed in 

accordance with the California Environmental Quality Act (CEQA). They are designed 

to ensure that TAC chlorinated solvents, compounds with higher GWP values, and 

certain surfactants are not used to meet new and lower VOC limits. Other amendments 

would clarify and improve existing regulatory provisions. The regulation is codified in 

title 17, California Code of Regulations, sections 94507-94517. 

Amendments to the analytical method “Determination of Volatile Organic Compounds in 

Consumer Products and Reactive Organic Compounds in Aerosol Coating Products” 

(Test Method 310) are also proposed. The amendments would set forth analytical 

methods and procedures to be followed to determine the VOC content of “Fabric 

Softener-Single Use Dryer Product” and the aromatic compound content of “Paint 

Thinner” and “Multi-purpose Solvent” products. 

This Executive Summary, together with the Technical Support Document, is the Initial 

Statement of Reasons for Proposed Rulemaking required by the California 

Administrative Procedure Act. Appendices A and B contain the amendments to the 

Consumer Products Regulation, and Test Method 310, respectively. The proposed 

changes are shown in underline and strikeout format. 

Among other things, this Executive Summary provides a description of the proposed 

amendments to the Consumer Products Regulation and to Test Method 310, and 

explains the rationale for the proposed changes. In accordance with Government Code 
Executive Summary - 2 

section 11346.2(a)(1), a “plain English” summary of the proposal is provided in 

Chapter VI of the Technical Support Document. 

A. Authority to Regulate Consumer Products

Consumer products are chemically formulated products used by household and 

institutional consumers. Examples include detergents; cleaning products; floor finishes; 

personal care products; lawn and garden products; air fresheners; disinfectants; 

automotive specialty products; paint thinners; insecticides; and aerosol paints. 

The Health and Safety Code sets forth ARB’s authority to regulate consumer products 

to control VOC emissions and greenhouse gas (GHG) emissions. Section 41712 

specifies requirements to reduce VOC emissions as a ground-level ozone control 

strategy. Section 38500 et seq., establishes authority to reduce emissions of GHGs

from consumer products as part of ARB’s climate change mitigation strategy. 

B. Existing Regulations 

Over the last twenty years, the Board has taken numerous actions to fulfill the legislative 

mandates pertaining to the regulation of consumer products. Five regulations have 

been adopted. Three regulations have set VOC limits for 127 consumer product 

categories. The adopted limits, when fully effective, will have resulted in reducing 

emissions by about 225 tons per day, an overall 50 percent reduction in VOC emissions 

compared to 1990 levels. By 2020, limits on the use of ingredients with higher GWP 

values will be equivalent to reducing about 0.23 million metric tons of carbon dioxide 

equivalents per year. 

We have also reduced exposure to TACs. Emissions of TACs have been reduced by 

over 13 tons per day by prohibiting use of chlorinated compounds in 72 categories. 

Two regulations, the Alternative Control Plan and the Hairspray Credit Program, have 

been adopted to provide compliance flexibility to companies. 

These five regulations are codified in title 17, California Code of Regulations, 

sections 94500 to 94575. 

C. Regulatory Development Process

In order to involve the public, the Consumer Products Regulation Workgroup (CPRWG), 

was formed. Participation in the CPRWG is open to any member of the public. The 

CPRWG participated in the development of the 2006 Consumer and Commercial 

Products Survey (2006 Survey) and the 2008 Survey for Dry Clean Only Spot Remover 

products (2008 Survey Update). The CPRWG was instrumental in the development of 

these proposed amendments. Consumer product manufacturers; chemical producers; 
Executive Summary - 3 

marketers; trade associations; environmental groups; air districts; and various other 

stakeholders are all active participants. 

In addition to the CPRWG meetings, an initial public workshop was held in August of 

2008, to begin the public process of developing this proposal. Two more public 

workshops to discuss proposals were held on April 13, 2010, and July 29, 2010. Prior 

to the public workshops we posted materials to the consumer products program website 

for review and comment. Stakeholders could participate in person or via teleconference 

at each workshop. In addition to these public meetings, numerous meetings with 

individual stakeholders and associations were held. 

D. Basis for the Proposal and VOC Emissions 

Emissions of VOCs from consumer products contribute to the formation of both groundlevel ozone and particulate matter pollution. This section focuses on reducing VOCs as 

a ground-level ozone control strategy. Despite reducing emissions by 225 tons per day, 

it is estimated that the 2010 consumer products emissions are approximately 245 tons 

per day, or about 12 percent of the overall statewide VOC inventory. We also estimate 

that the 2010 consumer product emissions comprise about 18 and 7 percent of VOC 

emissions in the South Coast Air Quality Management District (SCAQMD) and the San 

Joaquin Valley Air Pollution Control District (SJVAPCD), respectively. Without further 

actions, consumer product emissions are expected to grow to approximately 270 tons 

per day statewide in 2020, representing almost 14 percent of statewide VOC emissions 

(ARB, 2009a). 

The categories for which VOC limits are proposed in this rulemaking emit about 22 tons 

per day of VOCs. The basis for this estimate is the 2006 Survey and the 2008 Survey 

Update. The 2006 Survey was mailed to over 5,000 companies in July 2007. Over 

570 companies responded to the 2006 Survey with information on over 12,000 products 

(ARB, 2007e). The 2008 Survey Update was sent to manufacturers of spot removers 

primarily used at dry cleaning operations in January 2009. Eight companies responded 

with information on about 50 products (ARB, 2009e). 

The 2006 Survey and 2008 Survey Update provided staff with detailed information on 

the formulations of consumer products proposed for regulation. Data summaries from 

the 2006 Survey and the 2008 Survey Update were posted to the website and input 

from industry was used to correct inaccuracies in the data. For this rulemaking, the 

emissions data from the 2006 Survey and the 2008 Survey Update were grown by 

population to predicted 2010 emissions. Staff is confident that the 2006 Survey and 

2008 Survey Update had adequate representation of the available technologies in the 

market place for the categories proposed for regulation and finds that the data are 

adequate to support the proposal. 
Executive Summary - 4 

E. Consumer Product VOC Emission Reduction Commitments in the State 

Implementation Plan (SIP) 

Reduction of VOC emissions is necessary to attain the ambient air quality standards for 

ozone. In 1988, with the passing of the California Clean Air Act, the importance of 

controlling emissions from consumer products was set forth. To meet the federal ozone 

standard, in 1994 emission reductions from consumer products became part of the SIP 

to meet the federal standard for ozone. 

The 2007 SIP, the State Strategy for California’s 2007 State Implementation Plan, is 

California’s plan to attain the national ozone standard of 0.08 parts per million (ppm) 

averaged over eight hours. In this SIP ARB committed to an additional 30 to 40 ton per 

day VOC reduction statewide from consumer products by January 1, 2014. 

Table ES-1 shows our progress and remaining reductions needed to meet the 

consumer products commitment in the SIP. As shown in the table, the adopted 

rulemakings from 2008 and 2009 will result in over 19 tons per day of reductions once 

fully effective. 

Table ES-1 

Consumer Product SIP Commitment and Progress to Date 

Consumer Products Rulemaking Statewide VOC Reductions 

(tons per day) 

June 2008 Amendments 4.5 (adopted) 

September 2009 Amendments 14.7* (adopted) 

2010 Amendments 

(this proposal) 6.7 (proposed) 

Additional Reductions from 

Consumer Product Categories ~ 4.0 – 14.0 (needed) 

Totals Reductions Needed by 

January 1, 2014 30 – 40 

 * Emission reductions of about 12.7 tons per day of this reduction occur in all areas of the 

 State except the South Coast Air Quality Management District (district has their own rule, 

 Rule 1143, for Paint Thinners and Multi-purpose Solvents) (ARB, 2009c). 

The amendments proposed in this rulemaking are the third increment of emission 

reductions toward fulfilling the SIP commitment for VOC reductions from consumer 

products. As shown, if adopted this proposal would contribute an additional 6.7 tons per 

day statewide toward the commitment. Additional rulemakings will be necessary to 

complete the commitment. 

F. Summary of Proposed Amendments to the Consumer Products Regulation

 

Amendments are proposed to the following sections of the regulation: section 94508 

“Definitions;” section 94509 “Standards for Consumer Products;” section 94510 

“Exemptions;” section 94512 “Administrative Requirements;” and section 94515 “Test 

Methods.” The proposed modifications to sections 94510 and 94515 are minor 
Executive Summary - 5 

clarifications to reference new sections or delete redundant language. The proposed 

amendments to the other sections are summarized below. A summary of proposed 

amendments to Test Method 310 is also provided. Chapter VI of the Technical Support 

Document contains more detailed information on each proposed requirement. 

1. Definitions (section 94508) 

Section 94508 “Definitions,” provides all of the terms used in the Consumer Products 

Regulation which are not self-explanatory. The proposed amendments to the 

Regulation include the modification of 16 definitions, and the addition of 3 new 

definitions. These definitions are necessary to define categories proposed for VOC 

limits, clarify products that are not subject to the VOC limits, or to improve the 

enforceability of the Consumer Products Regulation. We are also proposing a minor 

change to the definition for Artist’s Solvent/Thinner products to change the size criterion 

from 32 to 34 fluid ounces. This definitional change, as well as a several other definition 

proposals, are further explained in Chapter VI. 

2. Proposed Amendments to Standards for Consumer Products 

(section 94509) 

Amendments are being proposed to the Table of Standards. Several modifications are 

proposed to consolidate various prohibitions on use of TAC compounds and limits on 

use of compounds with higher GWPs. Also proposed are prohibitions on use of certain 

TACs, compounds with higher GWPs, and specific surfactants in several categories. 

 

 Table of Standards: section 94509(a) 

The proposed amendments would specify new or lower VOC limits for the product 

categories shown in Table ES-2. Together, VOC limits are proposed for 11 categories 

with 15 VOC limits. “Special-purpose Lubricant” products are not currently regulated, 

while the other categories are currently subject to VOC limits. However, in the case of 

“Spot Remover” and “Oven or Grill Cleaner,” additional products are proposed for 

inclusion. For all but one of the currently regulated categories we are proposing lower 

VOC limits. We are proposing to increase the current limit for nonaerosol “Oven or Grill 

Cleaner.” This proposal is explained below. The limits would become effective on 

December 31, 2012, or December 31, 2013. Where appropriate we are proposing 

separate limits for aerosol product forms to ensure feasibility. Other minor clarifications 

to the Table of Standards are also proposed. 

The categories with limits becoming effective by January 1, 2014, would be creditable 

toward the 2007 SIP commitment, and would result in VOC emission reductions of 

about 6.7 tons per day. As specified in the regulation, the effective date of the limits for 

products requiring Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), as well 

as Department of Pesticide Regulation (DPR) registration, would be one year after the 

effective date listed to allow adequate time for the State and federal registration 

process. Because of this, the reductions from Flying Bug Insecticide and Wasp or 
Executive Summary - 6 

Hornet Insecticide products would be credited toward a future SIP commitment. 

Reductions from these two categories total about 0.2 tons per day. 

Several of the proposed VOC limits for the categories listed in Table ES-2 warrant 

additional explanation. 

Proposal for “Oven or Grill Cleaner”: We are proposing to incorporate grill cleaning 

products into the existing Oven Cleaner category. To allow the previously unregulated 

grill cleaner products the necessary time to reformulate, proposed subsection 94509(q) 

would specify that the VOC limits do not apply to these products until 

December 31, 2012. 

Nonaerosol Oven Cleaner products are currently subject to a limit of 1 percent by 

weight. When this limit was adopted reported products relied on low or non-VOC 

caustic technologies. We have since learned of other technologies introduced to 

provide alternatives to caustic products. To accommodate the use of these 

technologies we are proposing to increase the current VOC limit to 4 percent by weight 

for nonaerosol Oven or Grill Cleaner products. To expedite providing this alternative, as 

proposed, the limit revision would become effective when the amendments become 

legally effective. This proposal results in a small shortfall of about 0.1 tons per day. 

However, other reductions from this proposal would offset this change. 

Proposal for “Spot Remover”: We are proposing to incorporate spot removers used for 

dry clean-only fabrics into the currently regulated “Spot Remover” category. These are 

primarily products used at dry cleaning operations. To accommodate the necessary 

time for these products to reformulate, we are also proposing to delay the effective date 

of the VOC limit for “Spot Remover” products from December 31, 2010, to 

December 31, 2012. This modification is proposed to allow adequate time for 

reformulation of the new products being included in the category. The proposal to 

extend the effective date is intended to simplify enforcement activities for this category; 

it would be difficult to discern the difference between the newly added products and 

those currently regulated. The proposal for the “Spot Remover” category would result in 

delaying about a 0.25 tons per day VOC reduction for 2 years. The newly added 

products would also be subject to the existing prohibition on use of methylene chloride, 

perchloroethylene, and trichloroethylene beginning December 31, 2012. 

Other Amendments to section 94509 

Proposed Consolidation of Prohibitions on Use of Toxic Compounds: Currently, several 

subsections within section 94509 specify provisions prohibiting use of several 

chlorinated TACs. We are proposing to consolidate all of these requirements into two 

tables that would be contained in proposed modified subsection (m). One table would 

include all of the categories where use of methylene chloride, perchloroethylene, and 

trichloroethylene is prohibited. A second table would include the categories where use 

of para-dichlorobenzene is prohibited. The modified subsection (m) would also 

consolidate the provisions that specify sell-through dates and exemptions for impurities 
Executive Summary - 7 

Table ES-2 

Proposed VOC Limits by Product Form, Emissions, and 

Reductions at Effective Date

Product Category 

Product 

Form 

2010 VOC 

Emissions* 

(tons per day)

Proposed 

VOC 

Limit 

(weight percent)

VOC 

Reduction** 

(tons per day)

Flying Bug Insecticide Aerosol 0.65 20 0.06+

Furniture Maintenance 

Product Aerosol 1.32 12 0.36 

General Purpose Cleaner Nonaerosol 12.04 0.5 3.73+

General Purpose Degreaser Nonaerosol 1.91 0.5 1.17 

Glass Cleaner Nonaerosol 3.34 3 0.41 

Heavy-duty Hand Cleaner or 

Soap Nonaerosol 0.79 1 0.53 

Metal Polish or Cleanser Aerosol 0.22 15 0.07 

Metal Polish or Cleanser Nonaerosol 0.20 3 0.15 

Oven or Grill Cleaner Aerosol 0.08 8 >0.0 

Oven or Grill Cleaner Nonaerosol 0.24 4 -0.12 

Special-purpose Lubricant Aerosol 0.26 25 0.10 

Special-purpose Lubricant Nonaerosol 0.18 3 0.13 

Spot Remover (Dry Clean 

Only) Aerosol >0.0 15 >0.0 

Spot Remover (Dry Clean 

Only) Nonaerosol 0.17 3 0.17 

Wasp or Hornet Insecticide Aerosol 0.31 10 0.14+

Total Emissions 2010 21.7 tons per day 

Total VOC Reductions 

Creditable Toward 2007 

SIP 

 

 6.7 tons per day 

Total VOC Reductions 

Creditable Toward Future 

Commitment 

0.2 tons per day 

 * Survey emissions adjusted for market coverage and grown to 2010 based on population 

 ** Emission reductions grown to effective date based on population 

 

+ Products subject to FIFRA and DPR registration requirement given an extra year to complete the 

 registration process 

(except no exemption for impurities is provided for para-dichlorobenzene). The 

modifications are proposed to simplify the regulation by making it easier to find the 

prohibitions on toxic compounds. 
Executive Summary - 8 

Proposed Additional Prohibitions on Use of Methylene Chloride, Perchloroethylene, and 

Trichloroethylene: New Table 94509(m)(1) also contains proposed prohibitions on use 

of methylene chloride, perchloroethylene, and trichloroethylene in “Metal Polish or 

Cleanser,” “Silicone-based Multi-purpose Lubricant,” and “Special-purpose Lubricant.” 

These prohibitions are proposed to ensure that use of these TACs does not occur as 

products are reformulated to meet the proposed VOC limits. The newly added “Spot 

Remover” products would be subject to the existing prohibition on use of these solvents. 

These prohibitions are proposed as a mitigation measure under the CEQA. 

Proposed Consolidation of Prohibitions on the Use of Any Chemical Compound that has 

a GWP Value of 150 or Greater: At present, several subsections contain prohibitions on 

the use of compounds that have GWP values of 150 or greater. We are proposing to 

consolidate these provisions into modified subsection 94509(n). Subsection (n) would 

also consolidate the provisions that specify sell-through dates and exemptions for 

impurities. The modifications are proposed to simplify the regulation by making it easier 

to find the prohibitions on use of compounds with GWP values of 150 or greater. 

Proposed Additional Prohibitions on the Use of Any Chemical Compound that has a 

GWP Value of 150 or Greater: In this rulemaking we are also proposing to limit the use 

of global warming compounds with higher GWP values in “Flying Bug Insecticide,” 

“Furniture Maintenance Product,” “Metal Polish or Cleanser,” “Special-purpose 

Lubricant,” “Spot Remover,” and “Wasp or Hornet Insecticide” products. These 

prohibitions are proposed to ensure that use of compounds with GWP values greater 

than or equal to 150 does not begin as products are reformulated to meet proposed 

VOC limits. The measure is proposed as a CEQA mitigation measure. 

Proposed Prohibition on Use of Alkylphenol Ethoxylate Surfactants: Alkylphenol 

ethoxylates are nonionic surface active agents (surfactants) used as wetting agents, 

emulsifiers, and dispersants in cleaning and degreasing products. Once into 

wastewater, alkylphenol ethoxylates do not readily degrade and they and/or their 

degradation products enter aquatic environments through wastewater treatment 

facilities and storm water. 

Alkylphenol ethoxylates, in particular octylphenol and nonylphenol ethoxylates, have 

been found to be toxic to aquatic species; they are hormone disruptors, with the primary 

concern focused on the estrogenic effects (David et al., 2009). Because of this, ARB 

staff consulted with staff of the State Water Resources Control Board (SWRCB). 

Information provided to SWRCB staff indicates that alkylphenol ethoxylates are found in 

measurable concentrations in California’s receiving waters. Moreover, SWRCB staff is 

concerned that any potential additional use could adversely impact aquatic species 

(SWRCB, 2010a; SWRCB, 2010b; SCCWRP, 2010; and SFEI, 2010). Therefore, ARB 

staff is proposing a mitigation measure in accordance with CEQA. As proposed, after 

December 31, 2012, use of alkylphenol ethoxylate surfactants would be prohibited from 

use in Oven or Grill Cleaner products and in the nonaerosol forms of General Purpose 

Cleaner, General Purpose Degreaser, and Glass Cleaner. A prohibition on use in 

nonaerosol Heavy-duty Hand Cleaner or Soap products would become effective 
Executive Summary - 9 

December 31, 2013. These prohibitions are proposed to ensure that use of these 

compounds does not occur as products are reformulated to meet the proposed VOC 

limits. This proposal would be contained in modified subsection 94509(m)(3). 

Staff also finds that replacements for alkylphenol ethoxylates are readily available. 

Alcohol ethoxylates, linear alkylbenzene sulphonates, and alkyl polyglucosides 

surfactants are considered to be effective and environmentally safer. Additional 

information on this proposal is contained in Chapter IX, Environmental Impacts, 

section E. 

Additional Modifications to Section 94509 to Accommodate New Subsections (m) 

and (n): Because of the proposals to consolidate various provisions into new 

subsections 94509(m) and (n), additional “clean up” modifications to various 

subsections are proposed. These modifications include deleting several subsections 

and re-lettering and reorganizing remaining subsections. The references to the various 

toxic compound prohibitions and the GWP limits within the Table of Standards would 

also be modified to reference new subsections or re-lettered subsections. 

3. Proposed Amendments to Administrative Requirements 

(section 94512) 

We are proposing to amend the Most Restrictive Limit provision contained in 

subsection 94512(a). Specifically, subpart (3) would be modified to clarify the 

regulation’s applicability when two defined categories exclude each other within their 

respective definitions. As proposed, when a definition for a specific category excludes 

another specific category, and vice versa, the product is subject to the VOC limit for 

whichever category is lower. 

G. Proposed Amendments to Test Method 310 

ARB Test Method 310 sets forth the analytical procedures and processes to determine 

the VOC content of consumer products. We are proposing to amend this method to 

incorporate additional testing procedures and standard test methods to analyze 

consumer products for compliance. These modifications are proposed to specify the 

procedures to be used to analyze for the aromatic compound content in “Paint Thinner” 

and “Multi-purpose Solvent” products, and the VOC content of “Fabric Softener-Single 

Use Dryer Product.” 

Proposed amendments to section 2 of Method 310 would include additional applicable 

test methods to analyze consumer products for compliance. 

New subsections are also being proposed. Proposed new subsection 3.3.8 would 

specify the procedures for analyzing for aromatic compound content in “Paint Thinner” 

and “Multi-purpose Solvent” products. New section 4.2.3 would specify the procedures 

for analyzing for the VOC content of “Fabric Softener-Single Use Dryer Product.” 
Executive Summary - 10 

H. Compliance with the Proposed Amendments 

Manufacturers have the flexibility to choose from a variety of formulation options to meet 

the applicable limits (see Chapter VII, Description of Product Categories). To comply 

with VOC limits, VOC solvents or propellants may need to be replaced, or partially 

replaced, with VOC exempt ingredients. This may require using VOC exempt 

compounds, or formulating with an exempt VOC propellant. Use of water or low vapor 

pressure (LVP) VOC compounds is also feasible. Manufacturers may also need to 

change the valve, container, delivery system, or the other components of the consumer 

product depending on the individual formulation. For each category and proposed VOC 

limit staff has determined feasible pathways toward reformulation. We also note that 

the survey data show that, in each category, products are already being sold that 

comply with the proposed VOC limits. Table ES-3 shows the number of products and 

percent of the market that would currently comply with staff’s proposed VOC limits. 

Table ES-3 

Summary of Complying Products and Complying Market Shares

 Product Category 

Product 

Form 

Proposed 

VOC Limit 

(weight percent)

Number of 

Complying 

Products/Total 

Products 

Percent 

Complying 

Market 

Share 

Flying Bug Insecticide Aerosol 20 18 / 51 55 

Furniture Maintenance Product Aerosol 12 37 / 87 10 

General Purpose Cleaner Nonaerosol 0.5 980 / 1518 69 

General Purpose Degreaser Nonaerosol 0.5 232 / 462 73 

Glass Cleaner Nonaerosol 3 165 / 298 10 

Heavy-duty Hand Cleaner or 

Soap Nonaerosol 1 113 / 255 30 

Metal Polish or Cleanser Aerosol 15 20 / 73 35 

Metal Polish or Cleanser Nonaerosol 3 96 / 154 78 

Oven or Grill Cleaner Aerosol 8 18 / 21 87 

Oven or Grill Cleaner Nonaerosol 4 81 / 90 > 95 

Special-purpose Lubricant Aerosol 25 64 / 168 47 

Special-purpose Lubricant Nonaerosol 3 166 / 224 97 

Spot Remover (Dry Clean 

Only) Aerosol 15 <5 / <5 <5 

Spot Remover (Dry Clean 

Only) Nonaerosol 3 16 / 49 46 

Wasp or Hornet Insecticide Aerosol 10 38 / 56 60 

Source: 2006 Consumer & Commercial Products Survey and 2008 Spot Remover Survey Update. 
Executive Summary - 11 

Staff concludes that technology exists, and is readily available to comply with the 

proposed limits in the timeframes provided. Staff has also proposed limits that are 

feasible without the use of compounds with GWPs of 150 or greater, alkylphenol 

ethoxylates, and the TACs methylene chloride, perchloroethylene, and 

trichloroethylene. 

Several reformulation options warrant further discussion. 

 LVP-VOC Glycol Ethers

Stakeholders, as well as ARB staff, had concerns that reformulations to comply with the 

VOC limits for various cleaning products could result in use of certain compounds that 

may pose adverse health impacts. Staff evaluated various reformulation options and 

identified use of LVP-VOC glycol ethers as one of several reformulation options. To 

fully evaluate whether use of LVP-VOC glycol ethers would pose potential health 

hazards, ARB staff consulted with the Office of Environmental Health Hazard 

Assessment (OEHHA). 

Based on available health effects data OEHHA developed draft provisional Reference 

Exposure Levels (REL) for a number of LVP-VOC glycol ethers. A REL is a 

concentration in air that is considered safe. However, due to lack of publicly available 

health effects data, large uncertainty factors were applied to the RELs. Further analysis 

by OEHHA determined that the RELs should not be used as a basis for regulatory 

action due to an overall lack of information on the toxicity of these compounds. OEHHA 

will continue to monitor developments in the toxicological literature and will re-evaluate 

the provisional RELS in the future, if needed (OEHHA, 2010). 

In addition, based on staff’s ongoing analysis of reformulation approaches we have 

concluded that use of these compounds is neither necessary, nor the preferred 

reformulation approach. This is because a large share of products that already comply 

with the proposed VOC limits for “General Purpose Cleaner” and “General Purpose 

Degreaser” do not rely on use of LVP-VOC glycol ethers. We also believe the proposed 

VOC limit for “Glass Cleaner” products is set at a level such that use of LVP-VOC glycol 

ethers is not needed. Nevertheless, we will monitor use of the LVP-VOC glycol ethers 

through regular surveys of the industry. 

 Acetone

Staff has identified use of acetone as a potential reformulation option in specific 

categories. Acetone is a low photochemically reactive compound that has been 

excluded from the definition of VOC. However, concerns with its use have been raised 

because it is an extremely flammable solvent. Although acetone may have limited use 

in some categories, as shown in Appendix D, ‘typical’ complying and noncomplying 

formulas used as a basis for our economic analysis did not include acetone. This 

indicates that other reformulations to comply are more likely. In other cases where it 

could be used it would be in small amounts or in products already labeled to warn 
Executive Summary - 12 

consumers of flammability concerns. Therefore, we do not believe any additional use of 

acetone would pose safety concerns. 

 Other Compliance Options

Manufacturers can also comply with the proposed amendments through the use of the 

Innovative Products Provision (IPP) which allows a product to exceed the VOC limit if it 

is clearly demonstrated that the “innovative” product will result in less VOC emissions 

than a complying product that meets the applicable VOC limit. 

Manufacturers can also comply with the proposed amendments through the use of the 

Alternative Control Plan (ACP) that allows emissions averaging of various regulated 

products throughout their product lines. 

I. Economic Impacts

The economic impacts of the proposed amendments are summarized below. Our 

complete analysis of these impacts is contained in Chapter VIII of the Technical Support 

Document. 

1. Overall Cost 

We estimate that the overall cost to comply with the proposed amendments is about 

$5 million per year for ten years, for a total of almost $50 million. This amount includes 

both recurring (e.g., raw materials) and nonrecurring (e.g., research and development) 

costs and is estimated based on assumptions specific to each category. The cost 

represents the average of low and high cost estimates and represents our prediction of 

the costs most likely to be incurred.

2. Cost-effectiveness 

Another measure of the economic impacts of the proposal is to determine the “dollars to 

be spent per pound of VOC reduced,” or cost-effectiveness (CE). The CE of the 

proposed amendments has been calculated to be about $0.98 per pound of VOC 

reduced. This is based on total expected emission reductions of about 6.9 tons per day 

(includes reductions occurring in 2014). The CE of Consumer Product Regulation 

amendments proposed in 2006, 2008, and 2009 was about $2.35, $6.23, and $0.29 per 

pound of VOC reduced, respectively. Thus, the CE of this proposal is within the range 

of previously adopted consumer products amendments. 

3. Return on Owner’s Equity (ROE) 

Another measure of the impacts of the proposed amendments on manufacturers is to 

determine the ROE. ROE is a calculation which compares a company’s percentage 

reduction in profitability after incurring the costs associated with the proposed 

amendments. In calculating ROE, we make the conservative assumption that 
Executive Summary - 13 

manufacturers will absorb all compliance costs without passing any of these costs on to 

the consumer. Our analysis found that the overall reduction in profitability ranges from 

about 1 percent to about 3 percent, with an average reduction in profitability of about 

1.6 percent. 

Based on the small reduction in profitability, we believe that overall, most affected 

businesses’ profitability will not be adversely affected. If they are unable to absorb all or 

a portion of the compliance costs, these costs will be passed through to the consumer. 

4. Impacts on California Businesses 

Because we believe that the proposed amendments would not significantly alter the 

profitability of most businesses, as shown in our ROE analysis, we do not expect a 

noticeable change in employment; business creation; elimination or expansion; and 

business competitiveness in California. However, the proposed amendments may 

impose economic hardship on businesses with very little or no margin of profitability. 

5. Increased Cost to Consumers 

As a result of this proposal, consumers may have to pay more for some products, 

depending on the extent to which manufacturers pass along their compliance costs. If 

all assumed compliance costs are passed on to the consumer, we estimate the cost per 

unit increase would range from negligible or no cost for a nonaerosol Glass Cleaner 

product to about $0.44 for a Heavy Duty Hand Cleaner or Soap product. The 

aforementioned costs do not include typical retail mark-up. 

6. Fiscal Impacts 

No significant adverse economic impacts to any local or State agency were identified. 

We are aware that the California Prison Industry Authority (PIA) manufactures some 

products for which VOC limits are proposed. Based on the 2006 Survey, the PIA 

manufactures nonaerosol “General Purpose Cleaner,” “General Purpose Degreaser,” 

and “Glass Cleaner” products. All of these reported products already comply with the 

proposed VOC limits for these categories. Therefore, we expect no impacts on the PIA. 

ARB will have costs for enforcing the proposed amendments. It is estimated that 

beginning in fiscal year 2012-13 the Enforcement Division will require an additional 

1.5 staff. The costs for these additional resources will need to be addressed in the 

future. 

J. Environmental Impacts 

The proposed amendments to the Consumer Products Regulation are primarily 

designed to reduce VOC emissions. Therefore, implementing the proposed VOC limits 

would have an overall positive impact on the environment by reducing exposure to 

ground-level ozone. Other proposed amendments would either have no impact or 
Executive Summary - 14 

would have beneficial impacts on the environment. No significant adverse impacts were 

identified, however several mitigation measures are proposed to ensure no adverse 

impacts would result. 

Once fully effective, VOC emissions would be reduced statewide by about 6.9 tons per 

day. Our qualitative health risk assessment concludes that because VOCs are ozone 

precursors, public health is further protected by reducing these emissions. The actual 

lowering of health risks has not been quantified. The reductions resulting from this 

proposal would be an incremental step toward achieving the State and federal ozone 

standards. 

In addition to ground level ozone impacts, we evaluated how implementing the 

proposed amendments would impact particulate matter (particularly secondary organic 

aerosols); climate change, stratospheric ozone depletion; solid waste disposal; water 

quality; and energy use. No potential adverse impacts were identified. However, our 

evaluation of potential use of several TACs, compounds with higher GWP values, and 

certain surfactants indicated that there was a potential for adverse impacts resulting 

from compliance with the proposed VOC limits. Therefore, to address these impacts 

staff is proposing mitigation measures in accordance with CEQA. A complete analysis 

of the potential environmental impacts of the proposal is contained in Chapter IX of the 

Technical Support Document. A summary of proposed mitigation measures follows. 

1. Prohibition on Use of Certain Toxic Air Contaminants 

A mitigation measure, in accordance with CEQA, is proposed to prohibit the use of the 

TACs methylene chloride, perchloroethylene, and trichloroethylene in “Metal Polish or 

Cleanser,” “Silicone-based Multi-purpose Lubricant,” and “Special Purpose Lubricant” 

products. These provisions are proposed in subsection 94509(m) and are designed to 

ensure that use of these solvents does not occur as products reformulate to meet VOC 

limits. This proposal would reduce toxic emissions by about 0.1 ton per day. 

2. Limit on Use of Global Warming Compounds 

Several compounds with higher GWPs could be used in reformulated products. To 

minimize climate change impacts from implementing the proposed VOC limits, we are 

proposing to prohibit use of compounds with GWP values of 150 or greater in “Flying 

Bug Insecticide,” “Furniture Maintenance Product,” “Metal Polish or Cleanser,” “Specialpurpose Lubricant,” “Spot Remover,” and “Wasp or Hornet Insecticide” products. These 

prohibitions are proposed to ensure that use of compounds with GWP values greater 

than or equal to 150 does not begin as products are reformulated to meet proposed 

VOC limits. These provisions are proposed in subsections 94509(n). This proposal 

would allow use of the propellant hydrofluorocarbon (HFC) 152a, but preclude the use 

of HFC-134a. This limit is also proposed as a mitigation measure under CEQA. 
Executive Summary - 15 

3. Prohibition on Use of Alkylphenol Ethoxylate Surfactants 

Alkylphenol ethoxylates are nonionic surface active agents (surfactants) used as wetting 

agents, emulsifiers, and dispersants in cleaning and degreasing products. For some 

categories one reformulation pathway to the meet proposed VOC limits would be to 

replace VOC solvents with surfactants. Alkylphenol ethoxylates meet the definition of 

LVP-VOC so their use is not currently restricted by the VOC limits in the Consumer 

Products Regulation. In the cleaning/degreasing categories, because of how the 

products are used, some product is washed ‘down the drain.’ Once into wastewater, 

alkylphenol ethoxylates do not readily degrade and they and/or their degradation 

products enter aquatic environments through wastewater treatment facilities and storm 

water. 

Ample scientific evidence implicates the alkylphenol ethoxylates, particularly the 

octylphenol and nonylphenol ethoxylates, as toxic to aquatic species. Therefore, as a 

mitigation measure under CEQA, we are proposing that use of alkylphenol ethoxylate 

surfactants would be prohibited from use in Oven or Grill Cleaner products and in the 

nonaerosol forms of General Purpose Cleaner, General Purpose Degreaser, and Glass 

Cleaner products effective on December 31, 2012. We are also proposing that the 

alkylphenol ethoxylate surfactants be prohibited from use in Heavy-duty Hand Cleaner 

or Soap products effective December 31, 2013. These prohibitions are proposed to 

ensure that use of these compounds does not occur as products are reformulated to 

meet the proposed VOC limits. This proposal would be contained in modified 

subsection 94509(m)(3). 

K. Environmental Justice 

This proposal is consistent with the ARB’s Environmental Justice Policy to reduce 

health risks in all communities, including low-income and minority communities. 

Generally, use of consumer products is fairly uniform across the State, tracking with 

population, and their emissions are spread over the course of a day, rather than 

concentrated at a particular time of day. For these reasons, we do not believe that 

people of any given race, culture, or income would be more impacted than any others 

would. All Californians should benefit equally from the reduction in VOC emissions from 

the consumer product categories proposed for regulation. 

L. Future Plans

Future activities include continued review of the 2006 Consumer and Commercial 

Products Survey to determine if more VOC reductions are feasible. We also plan to 

conduct an additional survey to update emissions of aerosol coating products and 

various other consumer products. This survey will serve as the basis for completing the 

SIP commitment for consumer products. 
Executive Summary - 16 

We also will explore options for identifying complying products destined for sale in 

California and develop advisories to clarify what constitutes “incidental use” and to 

clarify how limits for “general” purpose products are enforced. 

M. Recommendation

We recommend that the Board adopt these proposed amendments to the Consumer 

Products Regulation and Test Method 310. 

REFERENCES 

1. Air Resources Board. The California Almanac of Emissions and Air Quality –

2009 Edition. 2009. (ARB, 2009a) 

2. Air Resources Board. Initial Statement of Reasons, Proposed Amendments to 

the California Consumer Products Regulations. August 7, 2009. (ARB, 2009c) 

3. Air Resources Board. 2008 Consumer & Commercial Products Survey Update 

for Dry Clean Only Spot Removers. January 14, 2009. (ARB, 2009e) 

4. Air Resources Board. 2006 Consumer & Commercial Products Survey (Including 

Aerosol Coating Products). July 24, 2007. (ARB, 2007e) 

5. David, A., Fenet, H., Gomez, E. Alkylphenols in Marine Environments:

Distribution Monitoring Strategies and Detection Considerations. 2009. Marine 

Pollution Bulletin. Volume 58: 953-960. (David et al., 2009) 

6. Office of Environmental Health Hazard Assessment. Provisional Reference 

Exposure Levels (RELS) Compounds of Interest As Possible LVP-VOCS. 

Memorandum dated September 16, 2010, from Melanie Marty, Ph.D., Chief, Air 

Toxicology and Epidemiology Branch, Office of Environmental Health Hazard 

Assessment, to Janette Brooks, Chief, Air Quality Measures Branch, Air 

Resources Board. (OEHHA, 2010) 

7. San Francisco Estuary Institute. Occurrence of Alkylphenol Ethoxylate 

Surfactants in San Francisco Bay and Potential Impacts on Water Quality. 

Memorandum dated July 13, 2010, from Rainer Hoenicke, Ph.D., Executive 

Director, San Francisco Estuary Institute, to Darrin Polhemus, Deputy Director, 

Division of Water Quality, State Water Resources Control Board. (SFEI, 2010) 

8. Southern California Coastal Water Research Project. Effects on Water Quality of

Alkylphenol Ethoxylate Surfactants (APEOs). Memorandum dated July 15, 2010, 

from Keith Maruya, Principle Scientist, Southern California Coastal Water 

Research Project, to Darrin Polhemus, Deputy Director, Division of Water 

Quality, State Water Resources Control Board. (SCCWRP, 2010) 
Executive Summary - 17 

9. State Water Resources Control Board. Water Quality Effects of Alkylphenol 

Ethoxylate Surfactants. Memorandum dated September 20, 2010, from Darrin,

Deputy Director, Division of Water Quality, State Water Resources Control 

Board, to Richard Corey, Chief, Stationary Source Division, Air Resources Board. 

(SWRCB, 2010a) 

10. State Water Resources Control Board. Effects on Water Quality of Alkylphenol 

Ethoxylate Surfactants. Memorandum dated July 19, 2010, from Valerie Connor, 

Ph.D., Deputy Director, Office of Information Management and Analysis, State 

Water Resources Control Board, to Darrin, Deputy Director, Division of Water 

Quality, State Water Resources Control Board. (SWRCB, 2010b) 
Intentionally Blank Page - 18 
State of California 

AIR RESOURCES BOARD

Initial Statement of Reasons for Proposed Amendments to the 

California Regulation for Reducing Emissions from 

Consumer Products 

and 

Test Method 310: “Determination of Volatile Organic Compounds in 

Consumer Products and Reactive Organic Compounds in 

Aerosol Coating Products” 

Technical Support Document 

Technical Support Document Chapter I - 1 

Chapter I. Introduction 

In this rulemaking Air Resources Board (ARB) staff is proposing amendments to the 

Regulation for Reducing Emissions from Consumer Products (Consumer Products 

Regulation) that are designed to reduce the volatile organic compound (VOC) content of 

various consumer products. Mitigation measures are also proposed to ensure that use 

of several toxic air contaminants, compounds with higher global warming potential 

(GWP) values, and certain surfactants are not used as replacements to meet the 

proposed VOC limits. Other proposals would clarify and improve existing regulatory 

provisions and definitions. The regulation is codified in title 17, California Code of 

Regulations, sections 94507-94517. The proposed amendments are necessary as an 

incremental step towards fulfilling the consumer products element of the 2007 State 

Implementation Plan for Ozone. 

Amendments to the test method used to verify consumer products’ compliance with 

VOC limits are also proposed. These amendments to Test Method 310: “Determination 

of Volatile Organic Compounds in Consumer Products and Reactive Organic 

Compounds in Aerosol Coating Products” (Test Method 310) are necessary to enforce 

newly adopted provisions in the Consumer Products Regulation. 

This Technical Support Document is ARB staff’s technical justification and analysis of 

the proposed amendments. It is part of the Initial Statement of Reasons (ISOR) for 

Proposed Amendments to the California Consumer Products Regulation and Test 

Method 310. The proposed amendments to the Consumer Products Regulation and 

Test Method 310 can be found in Appendices A and B, respectively, of this document. 

Included in this Technical Support Document is the following information: 

• background information on the consumer products program related to the 

control of VOC and greenhouse gas (GHG) emissions; 

• information on the public process used to develop the proposed amendments; 

 

• an overview of the requirements of State law and the State Implementation 

Plan commitment for consumer products; 

• an overview of air quality focusing on criteria pollutants and climate change 

which are germane to the regulation of consumer products; 

• a review of the emissions from the categories proposed for regulation and 

development of the VOC limits; 

• a description, in plain language, of the proposed amendments to the 

Consumer Products Regulation and Test Method 310; 
Technical Support Document Chapter I - 2 

• an analysis of the estimated economic impacts of the proposed amendments; 

• an analysis of the environmental impacts of the proposed amendments; and 

• a summary of future activities. 

A. Enabling Legislation 

The Health and Safety Code sets forth ARB’s authority to regulate consumer products. 

Section 41712 sets forth the authority to control VOC emissions to reduce ground-level 

ozone concentrations. Section 38500 et seq. provides the authority to reduce 

emissions of GHGs. Authority to mitigate potential adverse impacts of proposed 

regulations is set forth in Public Resources Code section 21000 et seq. A summary of 

each of these requirements in State law follows. 

1. Health and Safety Code section 41712 

In 1988, the California Clean Air Act (CCAA or “the Act”) added section 41712 to the 

California Health and Safety Code. The intent of section 41712 is primarily to reduce 

ground-level ozone concentrations. Section 41712, along with subsequent 

amendments, requires ARB to adopt regulations to achieve the maximum feasible 

reduction in VOC emissions from consumer products. The CCAA specified that 

attainment of the California State ambient air quality standards is necessary to promote 

and protect public health, particularly of children, older people, and those with 

respiratory diseases. The Legislature also directed that these standards be attained by 

the earliest practicable date. 

Prior to adoption, the Board must determine that adequate data exist to establish that 

the regulations are necessary to attain State and federal ambient air quality standards. 

Commercial and technological feasibility of the regulations must also be demonstrated. 

The Act further stipulates that regulations adopted must not eliminate any product form, 

and that recommendations from health professionals be considered when developing 

VOC control measures for health benefit products. 

2. Health and Safety Code section 38500 et seq.

In 2006, Assembly Bill (AB) 32, The California Global Warming Solutions Act of 2006, 

was signed into law. This law created a comprehensive, multi-year program to reduce 

GHG emissions in California. The California Health and Safety Code, commencing with 

section 38500, contains these provisions. AB 32 requires ARB to develop regulations 

and consider market-based compliance mechanisms that will ultimately reduce 

California’s GHG emissions to the 1990 baseline year by 2020. Beyond the 

requirements of AB 32, the Governor’s Executive Order EO-S-03-05 calls for an 

80 percent GHG reduction from 1990 levels by 2050. 

AB 32 required ARB to identify a list of “discrete early action greenhouse gas reduction 

measures” by June 30, 2007. Once on the list, these measures are to be developed 

into regulatory proposals, adopted by the Board, and made legally enforceable 
Technical Support Document Chapter I - 3 

(approved by Office of Administrative Law) by January 1, 2010. Reduction of 

compounds with higher GWP values that are used in consumer products was 

designated as one of these measures, and became part of the State’s comprehensive 

strategy when the Board approved the Scoping Plan on December 12, 2008. 

3. Public Resources Code section 21000 et seq.

In addition to requirements set forth in California's Health and Safety Code, the 

California Environmental Quality Act (CEQA) requires that environmental impacts of 

proposed regulations be evaluated. If significant adverse environmental impacts are 

identified, mitigation measures must be put in place, if available, to reduce or eliminate 

such impacts. California's Public Resources Code, commencing with section 21000 et 

seq., specifies these provisions. 

B. Background 

To date, the Board has taken numerous actions to fulfill the legislative mandate 

pertaining to the regulation of VOCs in consumer products. A synopsis of the 

regulations adopted to date follows. 

 1. Existing Consumer Product Regulations 

Three regulations have been adopted that affect 127 consumer product categories. 

These limits, once fully effective will result in reducing VOC emissions by about 

225 tons per day by the end of 2013, an overall 50 percent reduction. 

Exposure to toxic air contaminants (TAC) has also been reduced by prohibiting use of 

certain chlorinated compounds in 72 categories. Total emissions of TACs have been 

reduced by over 13 tons per day. 

In addition, two regulations, the Alternative Control Plan and the Hairspray Credit 

Program have been adopted to provide compliance flexibility to companies. The five 

consumer product regulations are codified in title 17, California Code of Regulations, 

sections 94500 to 94575: 

• Antiperspirants and Deodorants (Article 1, sections 94500-94506.5); 

• Consumer Products (Article 2, sections 94507-94517); 

• Aerosol Coating Products (Article 3, sections 94520-94528); 

• Alternative Control Plan (Article 4, sections 94540-94555); and 

• Hairspray Credit Program (Article 5, sections 94560-94575). 

Regulation of consumer products began in 1989 with adoption of the Antiperspirants 

and Deodorants Regulation. The “general” Consumer Products Regulation was 

approved in 1990 and has been amended numerous times. The most recent 

amendments to the Consumer Products Regulation were adopted on August 6, 2010. 

These amendments set new or lower VOC limits for three categories of consumer 

products. When fully effective VOC emissions from the 2009 amendments will be 
Technical Support Document Chapter I - 4 

reduced by an additional 14.7 tons per day. The Aerosol Coatings Regulation was 

adopted in 1995 and was amended in 2000. A complete summary of consumer 

products program regulatory actions with dates of regulatory amendments are provided 

in Appendix C. 

Greenhouse gas emission reductions of about 0.2 million metric tons of carbon dioxide 

equivalents (MMT CO2e) per year have also been achieved. 

2. Consumer Products and the State Strategy for California’s 2007 State 

Implementation Plan (SIP) 

Federal clean air laws require areas with unhealthy levels of ozone, carbon monoxide, 

nitrogen dioxide, sulfur dioxide and inhalable particulate matter to develop SIPs 

describing how they will attain national ambient air quality standards (NAAQS). A SIP is 

a compilation of new and previously submitted plans, programs (such as monitoring, 

modeling, permitting, etc.), local air district rules, and State and federal regulations. The 

Code of Federal Regulations (CFR) Title 40, Chapter I, Part 52, Subpart F, 

Section 52.220 lists all of the items which are included in the California SIP. 

The SIP showing how California's nonattainment areas will meet the eight-hour 

standard of 0.08 parts per million (ppm) was adopted at the September 25, 2007, Board 

hearing (ARB, 2007d). California's SIP was submitted to U.S. EPA in late 2007. As of 

this writing the U.S. EPA has not acted to approve this SIP. 

Specific to consumer products, in the SIP, ARB committed to reducing consumer 

product VOC emissions statewide by 30 to 40 tons per day by January 1, 2014. This 

means that all limits designed to meet this commitment must be effective before 

January 1, 2014. Rulemakings from 2008 and 2009 will result in over 19 tons per day of 

reductions once fully effective. The amendments proposed in this rulemaking are the 

third increment toward fulfilling the commitment for VOC reductions from consumer 

products. Additional information on the consumer products element of the SIP, 

including progress toward meeting the goal, is included in Chapter III. 

3. Consumer Products and the California Global Warming Solutions Act 

 of 2006 (AB 32)

Various consumer products may contain GHGs in their formulations. Most often these 

GHGs are propellants such as hydrofluorocarbons (HFCs) and carbon dioxide (CO2). 

To a lesser extent some GHGs are used as solvents. As mentioned earlier in this 

chapter greenhouse gas reductions from consumer products was designated a Discrete 

Early Action Measure. 

The Discrete Early Action Measure is a GHG emission reduction from consumer 

products estimated to be 0.25 MMT CO2e, if feasible. As mentioned previously, in 2020 

the reduction achieved will be 0.23 MMT CO2e. We continue to evaluate whether GHG 
Technical Support Document Chapter I - 5 

emission reductions from other consumer product categories are feasible, however, any 

additional measures would not be creditable to the Discrete Early Action Measure. 

 

4. National Consumer Products Regulations

On September 11, 1998, U.S. EPA promulgated a national consumer products 

regulation, the “National Volatile Organic Compound Emission Standards for Consumer 

Products” (40 CFR Part 59, Subpart C, Sections 59.201 et seq.). This action set 

national VOC emission standards for various categories of consumer products. The 

regulation became effective on September 11, 1998, and the VOC limits became 

effective on December 10, 1998, (U.S. EPA, 1998a). There are similarities and 

differences between the California and national consumer products regulations; 

however, the national regulation does not preclude states from adopting more stringent 

regulations. 

In 2011, U.S. EPA will begin working on amendments to their existing national 

consumer products regulation. Their amendments are based on California’s CONS-1 

(2004 Consumer Products Regulation Amendments) categories and limits. The 

amendments are expected to become effective in 2012, with a compliance date of 

January 2013. 

U.S. EPA has also promulgated a national regulation for aerosol coatings (spray paints) 

based on ARB’s Aerosol Coatings Regulation. This is a reactivity-based regulation. 

The national aerosol coatings regulation was promulgated on March 24, 2008. The 

compliance date was July 1, 2009 (U.S. EPA, 2008). 

The national consumer products regulation is less effective in reducing VOC emissions 

from consumer products. The national regulation does not regulate a number of 

product categories that are currently regulated under the ARB regulation. For the 

categories that are regulated under both regulations, many of ARB’s limits are more 

stringent than the national limits. Therefore, ARB’s consumer products regulations have 

achieved significant additional reductions over those that would be achieved by the 

national regulation alone. 

Because California has unique air quality problems, reducing VOC emissions from all 

categories, including consumer products, to the maximum extent feasible, is necessary 

to attain the federal and State ambient air quality standards for ozone. 

The national regulations for consumer products and aerosol coatings do not prohibit the 

use of certain TACs. To date, the California Consumer Products Regulation includes 

prohibitions on the use of certain TACs in 72 categories, resulting in a reduction of toxic 

compound emissions of over 13 tons per day. 

As of the date of this staff report, there are no national consumer products regulations 

related to reducing GHG emissions. 
Technical Support Document Chapter I - 6 

REFERENCES

1. Air Resources Board. State Strategy for California’s 2007 Implementation Plan. 

Released April 26, 2007. Adopted by the Air Resources Board on 

 September 27, 2007. (ARB, 2007d) 

2. United States Environmental Protection Agency. National Volatile Organic 

Compound Emission Standards for Aerosol Coatings; Direct Final Rule (40 CFR 

Parts 51 and 59). Federal Register: March 24, 2008. Volume 73, Number 57. 

(U.S. EPA, 2008) 

3. United States Environmental Protection Agency. National Volatile Organic 

Compound Emission Standards for Consumer Products. (40 CFR Part 59). 

Federal Register: September 11, 1998. Volume 63, Number 176: 48819-48847. 

(U.S. EPA, 1998a) 
Technical Support Document Chapter II - 7 

Chapter II. Public Process 

This chapter contains a description of the public process used to develop the proposed 

amendments. The Administrative Procedure Act (APA) (Government Code section 

11340 et seq.) requires that development of regulations must allow for public input. 

Our process for development of these proposed limits included a number of formal and 

informal opportunities for public participation. In order to involve the public, the 

Consumer Products Regulation Workgroup (CPRWG) was formed. Participation is 

open to any member of the public. The CPRWG participated in the development of the 

2006 Consumer and Commercial Products Survey (2006 Survey). The CPRWG 

actively participated in the development of the 2004, 2006, 2008, and 2009 

amendments, as well as, these proposed amendments. 

Further, the CPRWG also participated in the development of the 2008 Survey Update 

for Dry Clean Only Spot Remover Products (ARB, 2009e). The intent of this survey was 

to evaluate emissions from spot remover products used at dry cleaning facilities. The 

survey was conducted in response to comments from stakeholders that indicated the 

market was not sufficiently covered by the 2006 Survey (ARB, 2007e). Combined, 

these surveys serve as the basis for this proposal. 

Consumer product manufacturers, chemical producers, marketers, trade associations, 

and various other stakeholders listed below, have actively participated in the process. 

• American Chemistry Council (ACC) 

• American Cleaning Institute (ACI) 

• American Coatings Association (ACA) 

• Automotive Specialty Products Association (ASPA)

• Coalition for Clean Air 

• Consumer Specialty Products Association (CSPA) 

• Institute for Research and Technical Assistance (IRTA) 

• International Sanitary Supply Association (ISSA) 

• National Aerosol Association (NAA) 

• Personal Care Products Council (PCPC) 

Representatives from local air districts and agencies, including the South Coast Air 

Quality Management District (SCAQMD), and the United States Environmental 

Protection Agency (U.S. EPA) were also involved in the process. 
Technical Support Document Chapter II - 8 

ARB staff maintains a mailing list of over 5,000 companies and interested parties, 

including environmental organizations. We have established an electronic list serve, 

which has over 2,800 subscribers, to allow subscribers to receive pertinent information. 

We also have a public website for the 2010 Consumer Products Regulatory Work Group 

Activity. 

The public process to evaluate the categories included in these proposed amendments 

began in July of 2007 with release of the 2006 Survey. The Survey (along with the 

2008 Survey Update) provided detailed information on sales and product volatile 

organic compound (VOC) content which allowed for calculation of emissions and 

identified possible reformulation strategies to reduce VOC content. 

To begin this rulemaking process, on August 15, 2008, staff posted data summaries for 

several cleaning product categories to the CPRWG activity website. Draft VOC limits 

for these categories were posted on August 22, 2008. The data and proposals were 

discussed at a public workshop on August 27, 2008. At the meeting, staff discussed the 

draft regulatory categories, proposed limits, and the rulemaking timeline. The meeting 

served as a forum for stakeholder comments on the proposals. Based on comments 

received, staff postponed consideration of the proposals to assess health impacts 

associated with potential reformulation strategies. 

Staff continued review of the 2006 Survey and on October 19, 2009, data summaries 

were posted for the remaining 2006 Survey categories. Corrections to the data were 

made, as appropriate, based on stakeholder comments. 

The data summaries were evaluated for potential VOC reduction opportunities. Based 

on this review, draft categories and VOC limits for various categories were posted to the 

CPRWG activity website on April 8, 2010. The data and proposals were discussed at a 

second public workshop on April 13, 2010. At the meeting, staff discussed the draft 

regulatory categories, proposed limits, and the rulemaking timeline. Stakeholders 

participated in person and via teleconference. Useful comments on the proposals were 

received. These comments led to additional evaluation of the survey data, and in some 

instances resulted in modifications to the proposal to ensure commercial and 

technological feasibility of each proposed limit. 

To solicit additional information and comments, staff held individual meetings and 

teleconferences with stakeholders. At several of these meetings, industry 

representatives presented technical information related to reformulation of products. 

A third public workshop to discuss the proposal was held on July 29, 2010. As with 

each of the previous public workshops, stakeholders participated in person and via

teleconference. Prior to the public workshop materials to be discussed were posted to 

the 2010 CPRWG activity website. The proposal reflected some modifications based 

on comments received at earlier workshops. 
Technical Support Document Chapter II - 9 

REFERENCES 

1. Air Resources Board. 2008 Consumer & Commercial Products Survey Update for 

Dry Clean Only Spot Removers. January 14, 2009. (ARB, 2009e) 

2. Air Resources Board. 2006 Consumer & Commercial Products Survey (Including 

Aerosol Coating Products). July 24, 2007. (ARB, 2007e) 
Technical Support Document Intentionally Blank Page - 10 
Technical Support Document Chapter III - 11 

Chapter III. Statutory Requirements and the State 

Implementation Plan Commitment for 

Emission Reductions 

In this chapter, we describe State law requirements related to setting volatile organic 

compound (VOC) and greenhouse gas (GHG) limits, and how our proposals meet these 

criteria. Interpretation of the terms commercially feasible and technologically feasible is 

provided. The commitment for consumer products in the 2007 State Implementation 

Plan (SIP), and progress to date, are also described. 

A. VOC Reductions 

Health and Safety Code section 41712 gives the Air Resources Board (ARB) authority 

to control emissions from a very diverse number of products sold statewide to 

household and commercial consumers. By law, “Consumer Product" means a 

chemically formulated product used by household and institutional consumers, 

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

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

sanitizers; aerosol paints; and automotive specialty products; but does not include other 

paint products, furniture coatings, or architectural coatings. 

Section 41712 requires the Board to adopt regulations to achieve the maximum feasible 

reduction in VOCs emitted by consumer products after making certain determinations. 

Prior to adoption, the Board must determine that adequate data exist to establish that 

the regulations are necessary to attain State and national ambient air quality standards 

and the regulations are commercially and technologically feasible. Section 41712 also 

specifies that regulations cannot result in the elimination of a product form. Product 

form refers to the shape and/or structure of the product such as liquid; solid; powder; 

gel; crystal; aerosol; or pump spray. 

The Board must consider the effect that the limits or requirements proposed for health 

benefit products will have on the efficacy of those products in killing or inactivating 

agents of infectious diseases such as viruses, bacteria, and fungi. In this regard, the 

Board must consult with health professionals when developing VOC control measures 

for health benefit products. 

Section C provides the interpretation of the terms commercially and technologically 

feasible as they relate to setting VOC limits. During the early development of consumer 

product regulations, guidelines were established to ensure that these statutory criteria 

were met when setting limits. These guidelines and statutory criteria were followed in 
Technical Support Document Chapter III - 12 

developing the proposed amendments. Chapter V includes our rationale for why staff 

finds that the VOC limits meet these criteria. 

B. Greenhouse Gas Reductions 

Health and Safety Code section 38500 et. seq. (Assembly Bill 32) requires ARB to 

develop regulations and consider market mechanisms that will ultimately reduce 

California’s greenhouse gas emissions equivalent to the 1990 levels by 2020. It 

required ARB to identify a list of “discrete early action greenhouse gas reduction 

measures” by June 30, 2007. Reduction of compounds with higher global warming 

potential (GWP) values that are used in consumer products was designated as one of 

these measures, and is part of the State’s Scoping Plan. 

In accordance with section 38562, certain criteria are to be met in developing 

regulations to meet GHG reduction goals. Among other things, the regulations must be 

equitable, minimize costs, and maximize the benefits to California. The GHG 

regulations are also required to be technologically feasible and cost-effective. 

In this rulemaking, we are not proposing limits under the authority granted under 

Assembly Bill 32. We are, however, proposing a mitigation measure under authority 

granted by the California Environmental Quality Act to ensure that use of compounds 

with higher GWP values are not used to reformulate products to meet VOC limits. 

C. Interpretation of the Terms Technological and Commercial 

Feasibility in Relation to Proposing VOC Limits 

Staff bases proposals for VOC limits on the lower VOC content technologies reported 

within a product category, on technology transfer from other product categories, or on 

research into emerging technologies, that with lead time, will likely be feasible. In doing 

this, staff must ensure that the various product forms within each category will be 

preserved and that efficacy of health benefit products will not be affected. Our 

interpretation of the terms “technologically feasible” and “commercially feasible” follows. 

 1. Technologically Feasible

Health and Safety Code section 41712(b) requires that the Board adopt consumer 

product regulations that are “technologically feasible.” Technological feasibility is a 

different concept than "commercial feasibility," and does not take into account the cost 

of reformulating a product. We believe that a proposed limit is technologically feasible if 

it meets at least one of the following criteria: (1) the limit is already being met by at 

least one product within the same category, or (2) the limit can reasonably be expected 

to be met in the time frame provided through additional development efforts. 

In setting the proposed VOC limits, an effort was made, wherever possible, to ensure 

that multiple reformulation technologies exist which would allow products to comply. 

Proposed limits were set at VOC levels that staff determined could be met without 
Technical Support Document Chapter III - 13 

increased use of toxic air contaminants, greenhouse gases, or ozone-depleting 

compounds. General reformulation options include addition of exempt VOC solvents 

such as acetone, use of low vapor pressure (LVP)-VOC solvents, use of water-based 

technologies, use of VOC exempt propellants, increased use of surfactants, and use of 

inorganic compounds. 

2. Commercially Feasible 

Health and Safety Code section 41712(b) also requires the Board to adopt consumer 

product regulations that are “commercially feasible.” The term “commercially feasible” 

is not defined in State law. In interpreting this term, staff utilizes the reasoning 

employed by the United States Court of Appeals for the District of Columbia in 

interpreting the federal Clean Air Act. In the leading case of International Harvester 

Company v. Ruckelshaus, (D.C. Cir. 1973) 478 F. 2d 615, the Court held that the 

U.S. EPA could promulgate technology-forcing motor vehicle emission limits which 

might result in fewer models and a more limited choice of engine types for consumers, 

as long as the basic market demand for new passenger automobiles could be generally 

met. 

Following this reasoning, we have concluded that a regulation is “commercially feasible” 

as long as the “basic market demand” for a particular consumer product can be met. 

“Basic market demand” is the underlying need of consumers for a product to fulfill a 

basic, necessary function. This must be distinguished from consumer “preference,” 

which may be towards specific attributes of a particular product. A “preference” is the 

choice of consumers for a certain product or products based upon fragrance, cost, 

texture, etc. 

By way of example, a consumer has a basic market demand for a glass cleaner to 

remove soils, grease, dirt or grime from their windows. Glass cleaners may be 

formulated with glycol ether solvents or with ammonia. Consumers may choose an 

ammoniated glass cleaner because they prefer the performance characteristics, or they 

may choose a nonammoniated glass cleaner because they dislike the smell of 

ammonia. This distinction is not recognized by all parties. Some stakeholders have 

expressed the view that consumers do not have a “basic market demand” for a general 

class of products, but that consumers instead have a number of separate and distinct 

“basic market demands” for many specialty products with differing characteristics. 

ARB staff believes the consumer “preference” interpretation of “basic market demand” is 

inconsistent with the reasoning from the International Harvester case. To adopt such a 

narrow interpretation would be inconsistent with the clearly expressed legislative intent 

that “...the State board shall adopt regulations to achieve the maximum feasible 

reduction in reactive organic compounds emitted by consumer products...” (Health and 

Safety Code section 41712(a)). In order to achieve emission reductions, manufacturers 

of noncomplying products which perform the same basic function as complying product 

counterparts must reduce the amount of VOCs in their products. It is expected that 

when a product’s formulation changes, some attributes of the product will also change. 
Technical Support Document Chapter III - 14 

If ARB were to establish limits which accounted for every distinct feature of every 

product, then each product would require a limit unto itself. Using this approach, it 

would be impossible to achieve the maximum feasible reduction in VOC emissions. 

Most currently marketed products have some unique features that differentiate them 

from other products. Consumers who purchase a product have demonstrated a 

preference over other competing products. This distinction between “preference” and 

“basic market demand” was clearly made in the International Harvester case. In the 

International Harvester case, the court stated that the proposed emission limits would 

be feasible even though they may result in the unavailability of certain kinds of vehicles 

and engine types people preferred, as long as the basic market demand for passenger 

cars could be generally met. Applying this principle to consumer products, the 

proposed amendments allow the basic market demand to be met for each product 

category, even though it may no longer be possible to manufacture products with some 

specific attributes. ARB staff believes that this approach complies with Health and 

Safety Code section 41712. 

Chapter V of this report provides the rationale of why we believe the amendments 

proposed in this rulemaking meet these criteria. 

D. State Implementation Plans 

The Board must also meet its obligations under the SIP. Because VOCs are ozone 

precursors, specific consumer product control measures have been developed and 

included in SIPs to meet the previous one-hour peak ozone standard, as well as the 

eight-hour ozone standard. To meet the national standards, emission reductions from 

consumer products became part of the SIP for ozone in 1994. In this SIP, consumer 

products measures were put in place to work towards attaining the federal one-hour 

ambient air quality standard for ozone. In the 2003 SIP, ARB reiterated the commitment 

to reduce consumer products’ VOC emissions to meet the one-hour federal ozone 

standard. Our summary here focuses on the current consumer product element 

designed to meet the 0.08 parts per million (ppm) eight-hour ambient air quality 

standard for ozone (ARB, 2008b). 

1. The 2007 SIP Commitment for Consumer Products 

In 2007, a new SIP was adopted. This State Strategy for California’s 2007 State 

Implementation Plan continues California’s approach to attaining the federal ozone 

standard of 0.08 ppm averaged over eight hours (ARB, 2007d). The consumer 

products commitment in this SIP, to reduce VOC emissions by 30-40 tons per day 

statewide, supplements the 1994 and 2003 commitments. Table III-1 displays the 

progress toward meeting the January 1, 2014, deadline. Once fully effective the 

adopted limits from the 2008 and 2009 rulemakings will reduce VOC emissions by 

19.2 tons per day. 
Technical Support Document Chapter III - 15 

Table III-1 

Consumer Product SIP Commitment and Progress to Date

Consumer Products Rulemaking Statewide VOC Reductions 

(tons per day) 

June 2008 Amendments 4.5 (adopted) 

September 2009 Amendments 14.7* (adopted) 

2010 Amendments 

(this proposal) 6.7 (proposed) 

Additional Reductions from 

Consumer Product Categories ~ 4.0 – 14.0 (needed) 

Total Reductions by January 1, 2014 30 – 40 

 * Emission reductions of about 12.7 tons per day of this reduction occur in all areas of the 

 State except the South Coast Air Quality Management District (district has their own rule, 

 Rule 1143, for Paint Thinners and Multi-purpose Solvents) (ARB, 2009c). 

The amendments proposed in this rulemaking are the third increment toward fulfilling 

the 2007 SIP commitment for VOC reductions from consumer products. As shown in 

Table III-1, the proposal described in this report is designed to achieve a VOC reduction 

of about 6.7 tons per day statewide. Table III-1 also shows that additional rulemakings 

to complete the commitment are necessary. 

Further reductions from consumer products are important because VOC emissions from 

consumer products are predicted to become the largest source of VOC emissions in the 

South Coast Air Basin, and the third largest source in the San Joaquin Valley Air Basin 

by 2020. The SIP, in combination with local actions, provides emission reductions 

necessary to meet the eight-hour ozone standard in these two most challenging 

regions. 

VOC reductions from consumer products are becoming more difficult to achieve. In 

light of this, the SIP includes a commitment to explore innovative reduction approaches 

in the longer term. One such measure would include investigating emission reduction 

opportunities through reactivity-based standards. 

Alternative market-based mechanisms would also be explored to encourage the 

development, distribution, and purchase of cleaner, very low, or zero VOC emitting 

products. Examples of mechanisms to explore are an environmental product labeling 

program, programs where companies set their own emission reduction goals, and the 

use of print and broadcast media for public education. If these mechanisms cannot 

produce meaningful emission reductions from the consumer products source category, 

then other approaches would be evaluated. Some of these other approaches include 

the purchase of VOC emission reduction credits; and funding of special projects to 

reduce emissions or accelerate reductions from pollution sources outside of the 

consumer products industry. 
Technical Support Document Chapter III - 16 

2. Future SIPs 

Up-to-date information on SIP activities can be found on ARB’s website at: 

http://www.arb.ca.gov/planning/sip/sip.htm. Effective May 27, 2008, U.S. EPA reduced 

the eight-hour “primary” ozone standard to a level of 0.075 ppm. U.S. EPA also set a 

secondary eight-hour ozone standard to the level of 0.075 ppm, making it identical to 

the revised primary standard. As of this writing these standards have been withdrawn 

and are being reconsidered. U.S. EPA proposed that the new primary standard be in 

the range of 0.060-0.070 ppm. The final rule is expected by late October of this year 

(2010). Revisions to the current eight-hour standard will require that new SIPs be 

drafted. A complete new State strategy will be developed for 2013 (U.S. EPA, 2010c). 

The 2013 SIP will likely require more VOC reductions from consumer products. 

REFERENCES 

1. Air Resources Board. Initial Statement of Reasons, Proposed Amendments to 

the California Consumer Products Regulations. August 7, 2009. (ARB, 2009c) 

2. Air Resources Board. Ambient Air Quality Standards. April 1, 2008. 

 (ARB, 2008b) 

3. Air Resources Board. State Strategy for California’s 2007 Implementation Plan. 

Released April 26, 2007. Adopted by the Air Resources Board on 

September 27, 2007. (ARB, 2007d) 

4. International Harvester Company v. Ruckelshaus General Motors Corporation, 

478 F. 2d 615 (D.C. Cir., 1973) 

5. United States Environmental Protection Agency. National Ambient Air Quality 

Standards for Ozone (40CFR Parts 50 and 58). Federal Register: 

January 19, 2010. Volume 75, Number 11. (U.S. EPA, 2010c) 
Technical Support Document Chapter IV - 17 

Chapter IV. Air Pollutants, Area Designations, and 

Consumer Products’ Emissions 

California’s extreme air quality problems require unique strategies for improving air 

quality and slowing climate change. For example, nearly all Californians, or about 

99 percent, live in areas designated as nonattainment for the State’s ozone and/or 

particulate matter (PM) standards (ARB, 2009a). In this chapter, we provide an 

overview of air quality focusing on criteria pollutants and climate change problems 

which are germane to the regulation of consumer products. This chapter also includes 

a summary of national and State ambient air quality standards and displays areas of the 

State that are not in attainment with these standards. Information on consumer 

products emissions and emission trends is also provided. 

A. Criteria Pollutants 

National and State ambient air quality standards have been established to protect 

California’s population from the harmful effects of ozone and PM. An ambient air quality 

standard sets legal limits on the level of an air pollutant in the outdoor (ambient) air that 

has been deemed necessary to protect public health. Both ARB and U.S. EPA are 

authorized to set standards. 

Volatile organic compound (VOC) emissions from consumer products contribute to the 

formation of both ozone and fine PM. Other sources of VOCs include emissions from 

fuel combustion and various paint products. PM pollution is the result of both direct and 

indirect emissions. Direct sources of PM include emissions from fuel combustion and 

wind erosion of soil. Indirect PM emissions result from the chemical reaction of VOCs, 

nitrogen oxides (NOx), sulfur oxides, and other chemicals in the atmosphere. Emissions 

from consumer products are indirect sources of PM. 

 1. Ozone 

Ozone formation in the lower atmosphere results from a series of chemical reactions 

between VOCs and NOx in the presence of sunlight. The rate of ozone generation is 

related closely to both the amount and reactivity of VOC emissions as well as the 

amount of NOx emissions available in the atmosphere (Seinfeld and Pandis, 1998). 

Ozone is a colorless gas and the chief component of urban smog. It is one of the 

State’s most persistent air quality problems. Over 90 percent of the State’s population 

lives in areas where the State’s eight-hour ozone standard is exceeded (ARB, 2006b). 

Figure IV-1 below displays, by air basin, the number of days in 2007 that the State’s 

eight-hour ozone standard was exceeded. 
Technical Support Document Chapter IV - 18 

Figure IV-1 

Number of Days the State Eight-Hour Ozone Standard was Exceeded in 

Each Air Basin During 2007 

As shown in Figure IV-1, large areas of the State experience over 50 days per year of 

unhealthful air due to ground-level ozone concentrations that exceed the State 

standard. 

It has been well documented that ozone adversely affects the respiratory function of 

humans and animals. Research has shown that, when inhaled, ozone can cause 

respiratory problems, aggravate asthma, impair the immune system, and cause 

increased risk of premature death. Human health studies show that short-term 

exposure to ozone injures the lung (ARB, 2008b). In some animal studies, permanent 

structural changes with long-term exposures to ozone concentrations considerably 

above ambient were seen; these changes remain even after periods of exposure to 

clean air (U.S. EPA, 2006). Exposure to levels of ozone above the current ambient air 

quality standard can lead to lung inflammation, lung tissue damage, and a reduction in 

the amount of air inhaled into the lungs. 

Ozone is a strong irritant that can cause constriction of the muscle cells in the airways 

that result in symptoms such as coughing, chest tightness, shortness of breath, and 

increased asthma symptoms (ARB, 2008b). Recent evidence suggests that ozone may 

be linked to the onset of new asthma in very active children (McConnell et al., 2002). 

Ozone has also been associated with premature death. Ozone in sufficient doses can 
Technical Support Document Chapter IV - 19 

also increase the permeability of lung cells, rendering them more susceptible to toxins 

and microorganisms. Other health effects associated with ozone exposure include 

hospitalizations and school absences. The greatest risk from ozone exposure is to 

those who are active outdoors during smoggy periods, such as children, athletes, and 

outdoor workers. 

Not only does ozone adversely affect human and animal health, but it also affects 

vegetation, resulting in reduced yield and quality in agricultural crops, disfiguration or 

unsatisfactory growth in ornamental vegetation, and damage to native plants. During 

the summer, ozone levels are often highest in the urban centers in Southern California, 

the San Joaquin Valley, and Sacramento Valley, which are adjacent to the principal 

production areas in the State’s multibillion-dollar agricultural industry (USDA, 2010). 

ARB studies indicate that ozone pollution damage to crops is estimated to cost 

agriculture over $500 million dollars annually (ARB, 1987; ARB, 2006b). 

 2. Fine Particulate Matter 

Particulate matter is a complex mixture of tiny particles that may consist of dry solid 

fragments, solid cores with liquid coatings, and small droplets of liquid. These particles 

vary greatly in shape, size, and chemical composition, and can be made up of many 

different materials such as metals, soot, soil, and dust. As described above, PM can be 

directly emitted from sources, such as diesel PM, or can be produced indirectly from 

sources which emit precursors that are converted to PM by atmospheric processes. 

Particles 10 micrometers or less in diameter are defined as "respirable particulate 

matter" or "PM10." PM10 and particles 2.5 micrometers or less in diameter (PM2.5) can 

be inhaled deep into the lungs. PM2.5 contributes significantly to regional haze and 

reduction of visibility in California. Besides reducing visibility, the acidic portion of 

PM (nitrates, sulfates) can harm crops, forests, aquatic and other ecosystems 

(ARB, 2002). 

Considerable epidemiologic research over the past 15 years has investigated the 

responses of humans to PM. The principal health effects of PM exposure are 

summarized below: 

• Many studies have consistently found statistical associations between PM2.5 and 

premature death with both long-term (Pope et al., 2004; Pope et al., 2002; 

Krewski et al., 2000; Laden et al., 2006) and daily exposures (e.g., Dominici et 

al., 2005; Dominici et al., 2003; Laden et al., 2000). The association with 

premature mortality is considerably stronger for annual average PM2.5 exposure 

than for daily average PM2.5. That is, long-term exposure appears to pose a 

greater risk of death than short-term exposure. 

• A recent study suggests that long-term exposure to PM2.5 may influence the risk 

of adverse cardiovascular events in women (Miller et al., 2007), including 

hospitalization or death from heart attack or stroke. 
Technical Support Document Chapter IV - 20 

• Daily exposure to PM2.5 has been associated with hospitalization for heart and 

lung related causes (Moolgavkar, 2003; Zanobetti and Schwartz, 2003). Others 

have found that exposure to PM2.5 resulted in increased emergency room visits, 

exacerbation of asthma, and other respiratory diseases (Peel et al., 2005; 

Sheppard, 2003). Other research indicates that exposure to PM2.5 leads to 

increased asthma medication usage (Gent et al., 2003), and increased asthma 

symptoms (e.g., Delfino et al., 2002; Whittemore and Korn, 1980). Exposure to 

PM2.5 has also been associated with an increase in the loss of work days (Ostro 

et al., 1993; Ostro and Rothschild, 1989). 

• Older adults with pre-existing chronic heart or lung disease are at greatest risk of 

experiencing adverse effects related to PM2.5 exposure (Moolgavkar, 2003; 

Dominici et al., 2006; Symons et al., 2006). 

There is some evidence that PM and ozone may have greater effects in children than in 

adults. This may be because they inhale more PM2.5 and ozone per pound of body 

weight than do adults, and because they breathe more rapidly than adults. Adverse 

effects reported in children include reduced lung function and reduced lung growth in 

higher pollution areas (Gauderman et al., 2004; Gauderman et al., 2002; Gauderman et 

al., 2000) that may at least partially reverse if the child moves to an area with cleaner air 

(Avol et al., 2001); increased asthma and bronchitis symptoms (Gauderman et al., 

2005; McConnell et al., 1999); increased school absenteeism (Gilliland et al., 2001); 

and increased risk of acquiring asthma for children who engage in three or more 

outdoor sports and live in areas with high ozone concentrations 

(McConnell et al., 2002). 

 

B. Ambient Air Quality Standards 

To protect public health California has set two standards for ozone. The one-hour peak 

standard for ozone is 0.09 parts per million (ppm). The eight-hour standard for ozone is 

0.070 ppm averaged over eight hours. The PM10 annual average standard is 

20 micrograms per cubic meter (μg/m3) and the annual average PM2.5 standard is 

12 μg/m3

. The State PM10 standard for a 24-hour period is 50 μg/m3. The national and 

State ambient air quality standards for ozone and PM are shown in Table IV-1. 

Table IV-1 reflects the previous national eight-hour standard for ozone of 0.08 ppm. 

This is because the 0.075 ppm standard, promulgated on March 27, 2008, is being 

reconsidered. It is expected that the revised primary standard will be set within the 

range of 0.060 to 0.070 ppm to provide increased protection for children and other ‘at 

risk’ populations (U.S. EPA, 2010c). The final rule on the national standard is expected 

in October of this year. Table IV-1 shows that California's standards for PM and ozone 

continue to be more heath protective than those at the federal level. 
Technical Support Document Chapter IV - 21 

Table IV-1 

Ambient Air Quality Standards for Ozone, PM10 and PM2.5 

Pollutant Averaging Time State Standard National Standard

Ozone 1 hour 0.09 ppm 

(180 μg/m3) 

---------* 

8 hour 0.070 ppm 

(137 μg/m3) 

0.08 ppm** 

(157 μg/m3) 

PM10

24 hour 

Annual Arithmetic Mean 

50 μg/m3 

20 μg/m3

150 μg/m3 

--------- 

PM2.5

24 hour 

Annual Arithmetic Mean 

--------- 

12 μg/m3

35 μg/m3 

15.0 μg/m3

 Source: Air Resources Board, Ambient Air Quality Standards April 1, 2008 (ARB, 2008b). 

* The federal one-hour standard was revoked on June 15, 2005. 

** The previously promulgated standard of 0.075 ppm is being reconsidered. The 2007 SIP is designed 

 to reach attainment with the standard of 0.08 ppm (U.S. EPA, 2010c). 

1. Area Designations for California Ambient Air Ozone Standard 

The California Clean Air Act (CCAA) of 1988 has the fundamental goal that all areas of 

California are to attain the State ambient air quality standards for ozone by the earliest 

practicable date. As specified in the CCAA, ARB has designated areas of California to 

be in "attainment" or "nonattainment" for the State ozone standards. 

For the year 2010, Figure IV-2 shows the counties designated as nonattainment (or 

nonattainment transitional, which is a subcategory of nonattainment) for the State ozone 

standard. As shown, unhealthy levels of ozone are not limited to urban areas, but can 

be found in nearly every county in California. This map clearly indicates the extent and 

magnitude of the ozone problem in California. 

Some of the areas that are nonattainment for the State ozone standards are also 

nonattainment for the 0.08 ppm federal eight-hour ozone standard. SIPs showing how 

each nonattainment area would meet the 0.08 ppm eight-hour ozone standard were 

submitted to U.S EPA in 2007. In order to maintain progress towards clean air, the 

federal Clean Air Act prohibits backsliding on the control program. 

2. Area Designations for California Ambient Air PM2.5 Standard 

Figure IV-3 shows the counties designated as nonattainment for the State PM2.5 

standard. As with ozone, unhealthy levels of PM2.5 are not limited to urban areas, but 

can be found in many counties throughout California. 
Technical Support Document Chapter IV - 22 

Figure IV-2 

Area Designations for State Ambient Air Quality Standard for Ozone 

Nonattainment areas for the federal 24-hour PM2.5 standard of 35 μg/m3

 include the 

South Coast Air Quality Management District (SCAQMD); San Joaquin Valley Air 

Pollution Control District (SJVAPCD); Bay Area Air Quality Management District; 

Sacramento Metropolitan Air Quality Management District; and portions of the El 

Dorado County Air Quality Management District, Placer County Air Pollution Control 

District, Yolo/Solano Air Quality Management District, Feather River Air Quality 

Management District, Butte County Air Quality Management District, and Imperial 

County Air Pollution Control District. Thus, most of the areas shown in Figure IV-3 are 

also nonattainment for the federal 24-hour PM2.5 standard. SIPs are due to U.S. EPA 

for the federal 24-hour PM2.5 standard of 35 μg/m3 in 2012. 

 
Technical Support Document Chapter IV - 23 

Figure IV-3 

Area Designations for State Ambient Air Quality Standard for PM2.5 

SIPs for the federal PM2.5 annual standard of 15.0 μg/m3 were due to U.S. EPA in 2008. 

The PM2.5 SIP for SCAQMD was approved by the Board in September 2007 and was 

submitted to U.S. EPA in November 2007. The PM2.5 SIP for SJVAPCD was approved 

by the Board in May 2008 and was submitted to U.S. EPA in June 2008. 

C. Climate Change 

Climate change, or global warming, is the process whereby emissions of anthropogenic 

pollutants, together with other naturally-occurring gases, absorb infrared radiation in the 

atmosphere, leading to increases in the overall average global temperature. Changes 

in the atmospheric abundance of greenhouse gases (GHG) alter the energy balance of 

the climate system. These changes are expressed in terms of radiative forcing. The 

standard definition of “greenhouse gas” includes, but is not limited to, six substances as 

 
Technical Support Document Chapter IV - 24 

identified in the Kyoto Protocol; carbon dioxide (CO2), methane (CH4), nitrous oxide 

(N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride 

(SF6). 

The Global Warming Potential (GWP) of a compound may reflect a direct effect as well 

as an indirect effect on global warming. The direct effect is the warming due to the 

absorption of radiation by molecules of the compound in question. VOCs, CO2, and 

HFCs all have direct effects. The indirect effect is due to the impact that the presence 

of the compound has on the concentration of other GHGs. For example, VOCs 

contribute indirectly to global warming, because they react chemically in the atmosphere 

to increase GHG concentrations of ozone and methane. While VOCs do have direct 

effects, they are considered GHGs primarily because of their role in creating ozone, and 

in prolonging the life of methane in the atmosphere. 

By convention, the GWP index is defined relative to CO2 which has a GWP of 1. The 

Second Assessment Report (SAR) (IPCC, 1996), defines the GWP of a GHG as the 

ratio of the time-integrated radiative forcing impact from an instantaneous release of 

1 kilogram (kg) of a trace substance relative to that of 1 kg of CO2. The standard units 

of measurement used to express the emissions of a GHG is, million metric tons of CO2 

equivalents (MMT CO2e) per year. 

The GWP values used by ARB are generally the 1996 SAR GWP values (ARB, 2007c). 

These values are used when converting emissions of GHGs to CO2 equivalent values 

(CO2e). The SAR GWP values are used to be consistent with the Board’s Discrete 

Early Action Report, other statewide and national GHG inventories, and ARB’s Scoping 

Plan. When no SAR GWP value is listed, ARB uses the 2007 Fourth Assessment 

Report (FAR) GWP value (IPCC, 2007). 

The climate warming impact from emissions of GHGs is the product of two factors: 

(1) the mass of GHG emitted, and (2) its warming potential. In addition to uncertainty in 

the mass of emissions, there is also uncertainty in attributes of warming potential (as a 

function of direct and indirect warming impacts and the atmospheric lifetime) and thus in 

the assessment of GWP. 

D. Consumer Product Emissions 

Consumer products are a significant source of VOC emissions in California. These 

VOC emissions also contribute to secondary organic aerosol formation. The 

contribution of consumer products to overall GHG emissions is modest relative to other 

sources, such as vehicle exhaust. This section focuses on emissions of VOCs and 

GHGs. 

 1. VOC Emissions 

Although each consumer product may seem to be a small source of emissions, the 

cumulative use of these products by over 39 million Californians results in significant 
Technical Support Document Chapter IV - 25 

emissions (ARB, 2009a). Given the severity of the air pollution problems in California, 

further dramatic emission reductions from all sources contributing to ground-level ozone 

are necessary. 

As evidence of the magnitude of consumer product VOC emissions, it is estimated that 

current (2010) consumer products emissions are approximately 245 tons per day, or 

about 12 percent of the overall statewide VOC inventory. Consumer product emissions 

comprise about 18 percent and 7 percent of VOC emissions in SCAQMD and 

SJVAPCD, respectively. Without further actions, consumer product emissions are 

expected to grow to approximately 270 tons per day in 2020, representing about 

14 percent of statewide VOC emissions (ARB, 2009a). 

As control measures for other VOC sources (i.e. mobile sources) become effective, 

consumer product emissions become more important. For example, it is estimated that 

emissions from consumer products will be the largest source of VOC emissions in the 

SCAQMD in 2020. Given this, further reductions in VOC emissions from consumer 

products are needed, if ozone attainment is to be achieved and maintained. 

Despite these projections, ARB’s consumer products program has made significant 

progress. Since 1989, regulations adopted by the ARB, along with numerous 

amendments to the regulations, have substantially reduced VOC emissions from 

consumer products. Absent these regulations today, consumer product emissions 

would likely be about 450 tons per day. Figure IV-4 shows that statewide consumer 

product VOC emissions will have been reduced by over 225 tons per day by 2013. 

However, Figure IV-4 also shows that without further actions population growth would 

likely reverse the trend. 

The emission values in Figure IV-4 are derived from several data sources. The 1990 to 

2007 emissions are taken from the ARB Forecasted Emissions by Summary Category, 

2009 Almanac (ARB, 2007a; ARB, 2009b). Emissions are then grown in proportion to 

expected population increase. Population growth is in accordance with estimates in the 

California Environmental Protection Agency’s (Cal/EPA) Statewide Human Population 

Table found in the Population and Vehicle Trends Report (ARB, 2008c). For categories 

regulated by the 2009 Consumer Products Regulation Amendments, emission values 

from the 2006 Survey and estimated emission reductions resulting from the VOC limits 

approved by the Board at its September 2009, hearing, are reflected in the figure (ARB, 

2009c). As shown in Figure IV-4, the important emission reductions that have been 

realized from the ARB’s Consumer Products Program will, in 2014, begin to be offset by 

population growth. California’s population is expected to grow to 40 million by 2012 

(CA DOF, 2007). Therefore, ARB must continue its commitment to pursue additional 

technologically and commercially feasible consumer products emission reductions. 

 

2. Greenhouse Gas Emissions

Several GHGs are used in consumer products. Compounds of interest include CO2, 

N2O, HFCs, hydrochlorofluorocarbons, and hydrofluoroethers. However, the 
Technical Support Document Chapter IV - 26 

propellants CO2, HFC-134a, and HFC-152a are the predominate GHGs used in 

consumer products today. The propellants HFC-134a and HFC-152a are low 

Figure IV-4 

Consumer Products VOC Emission Trends 

225

250

275

300

325

350

375

400

425

450

475

500

525

1990199219941996199820002002200420062008201020122014201620182020

Year

Emissions (tpd)

Emissions (with population growth only)

Emissions (with population growth and emission reductions)

photochemically reactive compounds that are VOC exempt; they have been used as a 

reformulation strategy to reduce VOC content in other categories. CO2 is not a VOC. 

Using the second assessment report for GWP values, HFC-152a has a GWP of 140, 

while HFC-134a has a GWP of 1,300. The value for HFC-134a is approximately ten 

times greater than the GWP of HFC-152a and 1,300 times greater than CO2. Thus, 

consumer product emission reduction strategies have primarily focused on restricting 

the use of HFC-134a. 

REFERENCES 

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 (ARB, 2009b) 

225 tons 

per day 
Technical Support Document Chapter IV - 27 

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Technical Support Document Intentionally Blank Page - 32 
Technical Support Document Chapter V - 33 

Chapter V. Development of the Proposed VOC Limits 

In Chapter III information on statutory requirements and the State Implementation Plan 

(SIP) commitment was provided. Chapter IV focused on California’s air quality 

problems to demonstrate why there is a need to control emissions from consumer 

products. This chapter describes the development of the proposed limits and why we 

believe the limits are commercially and technologically feasible, and necessary. The 

following information is included: 

• surveys conducted to estimate emissions in categories proposed for regulation; 

• emissions from categories proposed for regulation;

• proposed volatile organic compound (VOC) limits and reductions resulting if the 

limits are adopted; 

• commercial and technological feasibility of the proposed VOC limits; 

• general reformulation strategies for noncomplying products; 

• necessity of achieving the reductions; and 

• alternative regulatory proposals considered. 

 

A. Surveys, Estimated Emissions, and Reductions from Categories 

Proposed to be Regulated 

In this section, we provide an overview of the surveys used to develop these proposed 

amendments. The survey data are used to estimate VOC and greenhouse gas (GHG) 

emissions from consumer products and evaluate opportunities for reductions. The 

categories, emissions, and proposed limits are also provided. 

1. Consumer and Commercial Products Surveys 

The 2006 Consumer and Commercial Products Survey was mailed to over 5,000 

companies in July 2007. The 2008 Dry Clean Only Spot Remover Survey Update (2008 

Survey Update) was sent to companies in January 2009. Over 570 companies 

responded to the 2006 Survey with information on over 12,000 products (ARB, 2007e). 

Eight companies responded to the 2008 Survey Update with information on about 

50 products (ARB, 2009e). The surveys were designed to obtain the comprehensive 

information necessary to develop new consumer product emission standards. Data 

received from these surveys formed the basis for the emissions used in this rulemaking. 

The 2006 Survey and 2008 Survey Update provided staff with detailed information on 

the formulations of consumer products proposed for regulation, including complete 
Technical Support Document Chapter V - 34 

speciation of VOCs, low vapor pressure VOC (LVP-VOC) solvents, GHGs, and key 

exempt ingredients (ARB, 2007e; ARB, 2009e). Total volumes of inorganic and other 

compounds were also provided. Information on sales, product form, customer types, 

and company size and economics was also obtained. 

Data summaries from the 2006 Survey and 2008 Survey Update were posted to the 

website and input from industry was used to correct inaccuracies in the data. For this 

rulemaking, the emissions data from the 2006 Survey and the 2008 Survey Update 

were grown by population to predict current year emissions (2010). Reported emissions 

were assumed to account for 90 percent of overall emissions. Data were also grown to 

ensure complete market coverage. Emission reduction estimates were grown to the 

date the limits become effective. The basis for these adjustments is the estimates in the 

California Environmental Protection Agency’s (Cal/EPA) Statewide Human Population 

Table found in the Population and Vehicle Trends Report (ARB, 2008c). 

Staff is confident that the 2006 Survey and 2008 Survey Update had adequate 

representation of the available technologies in the market place for the categories 

proposed for regulation and finds that the data meet the requirement in Health and 

Safety Code section 41712(b) to base regulations on “adequate data.” This assumption 

has been verified through data review by manufacturers, category research, shelf 

surveys, and the wide range of VOC content reported for products in the categories 

proposed for regulation. 

 

 2. Staff Evaluation of Emission Reduction Opportunities 

Development of the proposed amendments began with review of the survey data. In 

developing these proposals, staff worked with stakeholders on each category proposed 

for regulation. Numerous product labels and associated literature for each category 

were analyzed. Category information was also obtained from shelf surveys, trade 

journals, Internet sites, textbooks, patents, and directly from manufacturers. 

In developing the proposed amendments, staff reorganized survey categories based on 

similarities or other criteria. Staff further developed the proposed VOC limits for product 

categories based on technical information provided by stakeholders and staff's research 

efforts. 

As part of the public process, we presented specific proposals and alternatives to the 

public for consideration. Modifications were made to the original proposal after 

consideration and evaluation of comments. 

3. VOC Emissions, Proposed Categories, and Limits 

Based on the process described above, staff is proposing VOC limits for 11 categories. 

Table V-1 displays the statewide VOC emissions from the categories proposed for 

regulation. As shown in Table V-1, 2010 emissions are estimated to be about 21.7 tons 

per day. The table also includes the proposed VOC limit and emission reduction 
Technical Support Document Chapter V - 35 

Table V-1 

Proposed VOC Limits, Emissions, and Reductions at Effective Date

Product Category 

Product 

Form 

2010 VOC 

Emissions* 

(tons per day)

Proposed 

VOC 

Limit 

(weight %)

VOC 

Reduction** 

(tons per day)

Flying Bug Insecticide Aerosol 0.65 20 0.06+

Furniture Maintenance 

Product Aerosol 1.32 12 0.36 

General Purpose Cleaner Nonaerosol 12.04 0.5 3.73+

General Purpose Degreaser Nonaerosol 1.91 0.5 1.17 

Glass Cleaner Nonaerosol 3.34 3 0.41 

Heavy-duty Hand Cleaner or 

Soap Nonaerosol 0.79 1 0.53 

Metal Polish or Cleanser Aerosol 0.22 15 0.07 

Metal Polish or Cleanser Nonaerosol 0.20 3 0.15 

Oven or Grill Cleaner Aerosol 0.08 8 >0.0 

Oven or Grill Cleaner Nonaerosol 0.24 4 -0.12 

Special-purpose Lubricant Aerosol 0.26 25 0.10 

Special-purpose Lubricant Nonaerosol 0.18 3 0.13 

Spot Remover (Dry Clean 

Only) Aerosol >0.0 15 >0.0 

Spot Remover (Dry Clean 

Only) Nonaerosol 0.17 3 0.17 

Wasp or Hornet Insecticide Aerosol 0.31 10 0.14+

Total Emissions 2010 21.7 tons per day 

Total VOC Reductions 

Creditable Toward 2007 

SIP 

 

6.7 tons per day 

Total VOC Reductions 

Creditable Toward Future 

Commitment 

0.2 tons per day 

 * Survey emissions adjusted for market coverage and grown to 2010 based on population 

 ** Emission reductions grown to effective date based on population 

 

+ Products subject to FIFRA registration requirement given an extra year to complete the registration process 

at the date the proposed limits become effective. If adopted, VOC emission reductions 

from the limits that become effective prior to January 1, 2014, will be approximately 

6.7 tons per day. An additional reduction of about 0.2 tons per day would be realized by 

the end of 2014. Although important to overall air quality, these reductions from Flying 
Technical Support Document Chapter V - 36 

Bug and Wasp or Hornet Insecticide products will not occur within the timeframe to be 

credited toward the current SIP commitment. 

 4. Greenhouse Gas Emissions 

The GHGs reported in the categories proposed for regulation include CO2, 

hydrofluorocarbon-152a (HFC-152a), and hydrochlorfluorcarbon-141b (HCFC-141b). 

Reported emissions, in pounds per year, for CO2 are 41,145; for HFC-152a are 34,646; 

and for HCFC-141b are less than one pound per day. In combination, this is less than 

0.01 million metric tons per year of CO2 equivalents (MMT CO2e). 

B. Commercial and Technological Feasibility of the Proposed VOC 

Limits 

In accordance with State law staff must demonstrate that the limits are commercially 

and technologically feasible. Useful measures for evaluating feasibility are the number 

of products that currently comply with the proposed limits and/or the market share, 

based on sales, of those products. As shown in Table V-2, the complying market 

shares (except where confidential) range from about 5 percent to over 95 percent. For 

each category proposed for regulation, there are products on the market which currently 

comply. Where there is low complying market share, lower emission technology exists 

that can provide a pathway for compliance. Based on the complying market share 

and/or the number of complying products in each category, staff believes the proposed 

VOC limits are commercially and technologically feasible. 

In categories where the complying market share is low, staff has determined that the 

proposed effective dates will allow adequate time to successfully reformulate and bring 

products to market. Table V-2 also shows that for many categories separate limits have 

been proposed based on product form. This approach ensures that the proposed limits 

do not eliminate a product form, but also maximizes the reductions that are 

commercially and technologically feasible. 

C. Options for Complying with the Proposed VOC Limits 

Manufacturers of noncomplying products have the flexibility to choose from a variety of 

formulation options to meet the applicable limits. The reformulation options vary with 

each product category and are discussed in greater detail for each category in 

Chapter VII. To comply with VOC limits, VOC solvents or propellants will need to be 

replaced, or partially replaced, with non-VOC ingredients. This may require using 

water, exempt VOC compounds, substituting LVP-VOCs, increasing use of surfactants, 

increasing product solids, or formulating with a non-VOC propellant. Manufacturers 

may also need to change the valve, container, delivery system, or other components of 

the consumer product depending on the individual formulation. ARB staff has proposed 
Technical Support Document Chapter V - 37 

Table V-2 

Summary of Complying Products and Complying Market Shares

 Product Category 

Product 

Form 

Proposed 

VOC Limit 

(weight %)

Number of 

Complying 

Products/Total 

Products 

Complying 

Market 

Share (%) 

Flying Bug Insecticide Aerosol 20 18 / 51 55 

Furniture Maintenance Product Aerosol 12 37 / 87 10 

General Purpose Cleaner Nonaerosol 0.5 980 / 1518 69 

General Purpose Degreaser Nonaerosol 0.5 232 / 462 73 

Glass Cleaner Nonaerosol 3 165 / 298 10 

Heavy-duty Hand Cleaner or 

Soap Nonaerosol 1 113 / 255 30 

Metal Polish or Cleanser Aerosol 15 20 / 73 35 

Metal Polish or Cleanser Nonaerosol 3 96 / 154 78 

Oven or Grill Cleaner Aerosol 8 18 / 21 87 

Oven or Grill Cleaner Nonaerosol 4 81 / 90 > 95 

Special-purpose Lubricant Aerosol 25 64 / 168 47 

Special-purpose Lubricant Nonaerosol 3 166 / 224 97 

Spot Remover (Dry Clean Only) Aerosol 15 <5 / <5 <5 

Spot Remover (Dry Clean Only) Nonaerosol 3 16 / 49 46 

Wasp or Hornet Insecticide Aerosol 10 38 / 56 60 

Source: 2006 Consumer and Commercial Products Survey (2006 Survey) and 2008 Survey Update for Dry Clean 

Only Spot Removers (Survey Update) grown to 2010 based on population 

VOC limits that can be met without the increased use of toxic air contaminants, GHGs 

with higher GWP values, and certain surfactants. 

In general, we believe that aerosol products can and will be reformulated by reducing 

the amount of hydrocarbon propellant or using non-VOC propellants such as HFC-152a 

or CO2. Some modification to the valve/spray nozzle may also be needed. The VOC 

solvents will likely be replaced with LVP-VOC, or VOC exempt solvents. 

For nonaerosol products, developing water-based formulations is the most likely 

reformulation option for manufacturers of noncomplying products. We believe that VOC 
Technical Support Document Chapter V - 38 

solvents will be replaced with VOC exempt compounds; LVP-VOCs, such as methyl 

esters, glycol ethers, and hydrocarbons; surfactants; and/or inorganic compounds. 

Several reformulation options warrant further discussion. 

 LVP-VOC Glycol Ethers

Stakeholders, as well as ARB staff, had concerns that reformulations to comply with the 

VOC limits for various cleaning products could result in use of certain compounds that 

may pose adverse health impacts. Staff evaluated various reformulation options and 

identified use of LVP-VOC glycol ethers as one of several reformulation options. To 

fully evaluate whether use of LVP-VOC glycol ethers would pose potential health 

hazards, ARB staff consulted with the Office of Environmental Health Hazard 

Assessment (OEHHA). 

Based on available health effects data OEHHA developed draft provisional Reference 

Exposure Levels (REL) for a number of LVP-VOC glycol ethers. A REL is a 

concentration in air that is considered safe. However, due to lack of publicly available 

health effects data, large uncertainty factors were applied to the RELs. Further analysis 

by OEHHA determined that the RELs should not be used as a basis for regulatory 

action due to an overall lack of information on the toxicity of these compounds. OEHHA 

will continue to monitor developments in the toxicological literature and will re-evaluate 

the provisional RELs in the future, if needed (OEHHA, 2010). 

In addition, based on staff’s ongoing analysis of reformulation approaches we have 

concluded that use of these compounds is neither necessary, nor the preferred 

reformulation approach. This is because a large share of products that already comply 

with the proposed VOC limits for “General Purpose Cleaner” and “General Purpose 

Degreaser” do not rely on use of LVP-VOC glycol ethers. We also believe the proposed 

VOC limit for “Glass Cleaner” products is set at a level such that use of LVP-VOC glycol 

ethers is not needed. Nevertheless, we will monitor use of the LVP-VOC glycol ethers 

through regular surveys of the industry. 

 Acetone

Staff has identified use of acetone as a potential reformulation option in specific 

categories. Acetone is a low photochemically reactive compound that has been 

excluded from the definition of VOC. However, concerns with its use have been raised 

because it is an extremely flammable solvent. Although acetone may have limited use 

in some categories, as shown in Appendix D, ‘typical’ complying and noncomplying 

formulas developed for our economic impacts analysis did not include acetone. This 

indicates that reformulations not containing acetone are more likely. In categories 

where acetone could be used, the aerosol product form is already considered 

flammable due to the hydrocarbon propellant. Use of acetone in these products would 

not appreciably change how a consumer would use the product; consumers are already 

aware of the flammability hazard inherent in the use of aerosol products. In nonaerosol 
Technical Support Document Chapter V - 39 

products, we expect the reformulated products to contain water as the primary 

ingredient with small amounts of VOC solvents. If acetone were to be used in either 

nonaerosol or aerosol products, because only a relatively small amount of product is 

required to perform a specific task, the fire hazard is low. 

 Other Reformulation Options

Staff has identified that certain toxic compounds, GHGs, or surfactants could be used in 

reformulated products. Where necessary, staff is proposing mitigation measures to 

ensure that use of the toxic air contaminants methylene chloride, perchloroethylene, 

and trichloroethylene does not increase as products are reformulated. A specific 

mitigation measure is also proposed to ensure that use of GHG with GWP values at or 

above 150 does not begin. Another proposed mitigation measure would preclude use 

of the alkylphenol ethoxylate surfactants due to aquatic toxicity impacts. More 

information on each of these proposals is contained in Chapters VI, VII, and IX. 

 Options Other than Direct Compliance with the Proposed VOC Limits

Manufacturers can also comply with the proposed amendments through the use of the 

Innovative Products Provision (IPP), or the Alternative Control Plan (ACP). The IPP 

allows manufacturers of “innovative products” to comply with the Consumer Products 

Regulation if they demonstrate through clear and convincing evidence that their product 

will result in less VOC emissions than a complying product that meets the applicable 

VOC limit. The innovative product may result in less emissions due to some 

characteristic of the product formulation, design, delivery system, or other factors. 

The ACP allows a manufacturer to average the emissions from products above and 

below the applicable VOC limits, as long as the overall emissions are less than or equal 

to the emissions that would have occurred had all the products complied with the VOC 

limits. The manufacturer must submit an application which includes the VOC content of 

the products in the plan, a method of verifying the sales of each product in the plan, and 

other information necessary to track overall emissions. 

D. Necessity of Proposed Amendments 

Because significant further VOC emissions reductions are necessary to attain the 

national and State ozone standards, the reductions from the amendments proposed in 

this report are therefore “necessary” within the meaning of section 41712 of the Health 

and Safety Code. In addition, section 41712(b)(1) of the Health and Safety Code 

provides that the “necessity” of a regulation is to be evaluated in terms of both the State 

and federal standards. 

The applicable State and federal laws show that both the U.S. Congress and the 

California Legislature intended progress toward clean air be made as quickly as 

possible. The CCAA specifically declares that it is the intent of the Legislature that the 

State air quality standards be achieved “...by the earliest practicable date...” (See Health 
Technical Support Document Chapter V - 40 

and Safety Code, sections 40910 and 40913(a); see also the uncodified section 1(b)(2) 

of the Act (Stats. 1988, Chapter 1568)). A similar intent is expressed in the federal 

Clean Air Act, which declares that the federal air quality standards are to be achieved 

“...as expeditiously as practicable...” (See sections 172(a)(2), 181(a), and 188(c) of the 

federal Clean Air Act). For all of the reasons described above, the proposed 

amendments are “necessary” within the meaning of section 41712 of the Health and 

Safety Code. 

The amendments proposed in this rulemaking are the third increment toward fulfilling 

the 2007 SIP element for VOC reductions from consumer products. 

E. Alternatives Considered

Government Code section 11346.2 requires ARB to consider and evaluate reasonable 

alternatives to the proposed regulation and provide reasons for rejecting those 

alternatives. We identified three alternative approaches to the current proposal: “No 

action,” “set different limits,” and “set reactivity-based VOC limits.” Our rationale for 

rejecting these alternatives, in favor of the proposal chosen, follows. 

 Alternative One – No Action

A “no action” alternative would be to forego adopting the proposed amendments, or 

delay adoption of the proposed measures. The “no action” alternative would result in 

failing to make progress toward meeting our SIP commitment (see Chapter III). If the 

SIP commitments are not met, there is a potential that the State could lose federal 

funds. In addition, the citizens of California would not benefit from the improved air 

quality that would result from the reduction of emissions being proposed. This 

alternative would have no cost to business. 

Alternative Two – Set Different Limits

Staff thoroughly evaluated each category for which a limit is proposed. Limits were 

proposed based on low emitting technologies reported in the 2006 Survey and 2008 

Survey Update. Stakeholders provided additional information pertinent to the 

categories and, in some cases, proposed alternative limits. We evaluated all comments 

and determined the most feasible limit and effective dates from all of the alternatives 

proposed or considered. The final proposal contains limits that were determined to 

obtain the maximum feasible reduction, were commercially and technologically feasible, 

preserved product forms, maintained efficacy of health benefit products, and together 

achieved the necessary emission reductions to partially fulfill ARB’s SIP commitments. 

Alternative Three – Set Reactivity-based Limits

For each category staff determined the maximum feasible VOC reduction that could be 

achieved through proposing mass-based VOC limits. Staff then compared this 
Technical Support Document Chapter V - 41 

reduction to the reduction that could be achieved by proposing reactivity-based VOC 

limits. Staff found that mass-based limits provided the better air quality benefit. In 

some categories a small number of VOC ingredients are used making VOC substitution 

unfeasible. VOC substitution is the premise for reactivity-based VOC limits. In other 

categories, use of water and surfactant technology appears to be the most viable 

reformulation option. Use of this technology is negligibly reactive so again, there is little 

opportunity for substitution. Finally, in other categories the mass-based limits proposed 

resulted in greater air quality benefits. For all of these reasons we rejected the 

alternative to set reactivity-based limits. 

REFERENCES 

1. Air Resources Board. 2008 Consumer & Commercial Products Survey Update 

for Dry Clean Only Spot Removers. January 14, 2009. (ARB, 2009e) 

2. Air Resources Board. Statewide Human Population Chart: Population and 

Vehicle Trends Report. April 2008. (ARB, 2008c) 

3. Air Resources Board. 2006 Consumer & Commercial Products Survey (Including 

Aerosol Coating Products). July 24, 2007. (ARB, 2007e) 

4. Office of Environmental Health Hazard Assessment. Provisional Reference 

Exposure Levels (RELS) Compounds of Interest As Possible LVP-VOCS. 

Memorandum dated September 16, 2010, from Melanie Marty, Ph.D., Chief, Air 

Toxicology and Epidemiology Branch, Office of Environmental Health Hazard 

Assessment, to Janette Brooks, Chief, Air Quality Measures Branch, Air 

Resources Board. (OEHHA, 2010) 
Technical Support Document Intentionally Blank Page - 42 
Technical Support Document Chapter VI - 43 

Chapter VI. Plain Language Description of the Proposed 

Amendments to the Consumer Products 

Regulation 

In this chapter, we provide a plain language description of the proposed amendments to 

the California Regulation for Reducing Emissions from Consumer Products (Consumer 

Products Regulation) and explain the rationale and necessity for the proposals. The 

regulation is codified in title 17, California Code of Regulations, Division 3, Chapter 1, 

Subchapter 8.5, Article 2, Consumer Products, sections 94507-94515. A description of 

the proposed changes to test method “Determination of Volatile Organic Compounds 

(VOC) in Consumer Products and Reactive Organic Compounds in Aerosol Coating 

Products” (Method 310) is also included. 

The information in this chapter satisfies the requirements of Government Code 

section 11343.2, which requires that a noncontrolling “plain English” summary of the 

regulation be made available to the public. Where applicable, key terms or concepts 

involved in each proposed amendment are described. The proposed amendments to 

the Consumer Products Regulation and Method 310 can be found in Appendices A and 

B, respectively. 

Amendments are being proposed to the following sections in the Consumer Products 

Regulation: section 94508 “Definitions;” section 94509 “Standards for Consumer 

Products;” section 94510 “Exemptions,” section 94512 “Administrative Requirements,” 

and section 94515 “Test Methods.” 

A more detailed discussion of the existing regulatory requirements can be found in 

additional ARB publications which are referenced at the end of this chapter (ARB, 

2009c; ARB, 2008a; ARB, 2006a; ARB, 2004b; ARB, 1999; ARB, 1997b; ARB, 1991; 

ARB, 1990). 

Changes to Method 310 would modify section 2 to include additional applicable test 

methods to analyze consumer products for compliance. Proposed new subsection 

3.3.8 would specify the procedures for analyzing for aromatic compound content in 

“Paint Thinner” and “Multi-purpose Solvent” products. New subsection 4.2.3 is 

proposed to specify the procedures for analyzing for the VOC content of “Fabric 

Softener-Single Use Dryer Product.” 
Technical Support Document Chapter VI - 44 

In Chapter III we summarized the legal requirements that must be adhered to in the 

regulation of consumer products. In the sections below, we describe the proposed 

amendments and the rationale for them. 

A. Proposed Amendments to Section 94508(a): Definitions

Section 94508, “Definitions,” provides all the terms used in the Consumer Products 

Regulation which are not self-explanatory. The proposed amendments to the regulation 

include 3 new and 16 revised definitions. Table VI-1 lists the proposed new or modified 

definitions. These changes are necessary to improve clarity, improve enforceability, or 

to describe the types of products that are included or excluded from the product 

categories. Because of the proposed definitional changes, section 94508(a) would also 

be reorganized to reflect proper alphabetical order. Chapter VII, contains a detailed 

description of the products in each category for which a VOC limit is proposed, along 

with the proposed limits. 

Table VI-1 

Proposed New and Modified Definitions

Alkylphenol Ethoxylate * Lubricant 

Artist’s Thinner/Solvent Metal Polish/Cleanser 

Automotive Wax/Polish/Sealant/Glaze Multi-purpose Solvent 

Dry Cleaning Fluid Oven or Grill Cleaner 

Existing Product Sealant or Caulking Compound 

General Purpose Cleaner Silicone-based Multi-purpose Lubricant 

General Purpose Degreaser Special-purpose Lubricant * 

Gum or Candle Wax Remover * Spot Remover 

Lawn and Garden Insecticide Wasp and Hornet Insecticide 

Laundry Prewash 

 * New Definition 

Many of the proposed changes to definitions are minor clarifications. However, several 

of these proposed definitions warrant further discussion. 

 Alkylphenol Ethoxylate

We are proposing to add a definition for Alkylphenol Ethoxylate. An alkylphenol 

ethoxylate would be defined as a nonionic surface active agent (surfactant) composed 

of an alkyl chain of at least eight carbon atoms and a polyethoxylate chain attached to a 

benzene ring. Alkylphenol ethoxylate would include, but not be limited to, octylphenol 

ethoxylate (an alkyl chain consisting of eight carbon atoms), and nonylphenol ethoxylate 

(an alkyl chain consisting of nine carbon atoms). The definition is needed to implement 

our proposal to preclude use of these compounds in several categories. This is 

explained further in section B of this chapter. 

 
Technical Support Document Chapter VI - 45 

Artist’s Solvent/Thinner

At present, products meeting the definition of Artist’s Solvent/Thinner are limited to 

specific products sold in packages of 32 fluid ounces. We are proposing to modify the 

definition of Artist’s Solvent/Thinner to specify that an Artist’s Solvent/Thinner is a 

product packaged in a container of 34 ounces or less. This change is being proposed 

because staff has determined that Artist’s Solvents/Thinners are commonly packaged in 

metric units (i.e. a liter which is 33.8 ounces), rather than English units (i.e. a quart 

which is 32 ounces). Products sold in containers of this size (and meeting other criteria) 

are not subject to the VOC limits for Paint Thinner products. The proposed change 

would have negligible impacts on emissions because over the course of time, the same 

amount of thinner would be used. 

Automotive Wax, Polish, Sealant or Glaze

The Automotive Wax, Polish, Sealant or Glaze definition has been reorganized to clarify 

the various subcategories that meet the definition. 

 General Purpose Degreaser and Lubricant

We are proposing to clarify the exemption for General Purpose Degreaser and 

Lubricant products used at manufacturing facilities. At present these definitions exclude 

products that are sold exclusively to facilities that manufacture or construct goods or 

commodities, and that are labeled “not for retail sale.” We have determined that the 

phrase “not for retail sale” is inadequate to describe products used in the manufacturing 

process and that use of this term could allow for unintended products to meet this 

exemption criterion. We have also determined that in the normal chain of commerce, 

responsible parties for General Purpose Degreaser and Lubricant products sell products 

to distributors, who in turn, sell to manufacturing facilities. With this understanding, we 

are proposing to amend the exclusion to include distributors that sell directly to 

manufacturing facilities. To ensure that only products used in the manufacturing 

process itself meet the exclusion, we are proposing that these products be labeled “For 

Manufacturing Use Only.” The phrase “not for retail sale,” for the purposes of this 

regulation, would be deleted. As proposed, these provisions would become effective at 

the end of 2012. 

 Multi-purpose Solvent

Modification to the Multi-purpose Solvent definition is proposed to clarify that products 

that are labeled exclusively to clean a specific contaminant on a single substrate are not 

included in the Multi-purpose Solvent category. 

Oven or Grill Cleaner

The Oven Cleaner definition is proposed for modification to include grill cleaning 

products. We are also proposing to clarify that to be considered an Oven or Grill 
Technical Support Document Chapter VI - 46 

Cleaner, products must be labeled only for removing baked on cooking greases from 

food preparation and/or food cooking surfaces. The proposed modifications would also 

clarify the differences among “Oven or Grill Cleaner,” “General Purpose Cleaner” and 

“General Purpose Degreaser” products. 

Special-purpose Lubricant

Based on staff’s evaluation and results of the survey data we are also proposing to 

combine several special or single purpose lubricant products (nonsilicone-based) into a 

single category of Special-purpose Lubricant. The proposed new category would 

include cutting oils; tapping oils; anti-seize products; gear, chain, and wire lubricants; 

and rust preventative or rust control products that make lubricating claims. Food grade 

lubricants with these end functions would also be considered Special-purpose 

Lubricants. “Special-purpose Lubricant” would not include the other regulated 

categories “Multi-purpose Lubricant,” “Silicone-based Multi-purpose Lubricant,” 

“Penetrant,” products designed and labeled exclusively to release manufactured 

products from molds, and products designed or labeled to provide lubricity solely by 

depositing a thin film of graphite, molybdenum disulfide (“moly”) or 

polytetrafluoroethylene or closely related fluoropolymer (“teflon”) on surfaces. 

Spot Remover

At present, spotting agents used at commercial laundry and dry cleaning operations are 

excluded from the definition of Spot Remover. Comments were received that these 

products were formulated with toxic compounds and that the need for continuing to 

exclude these products should be evaluated. In response, staff surveyed these 

products and determined that these spotting agents should be regulated along with the 

currently regulated Spot Remover products. Therefore, we are proposing to modify the 

definition of “Spot Remover” to include Spot Removers used at commercial dry cleaning 

and laundry operations. 

To implement this proposal minor clarifications to the definitions for “Laundry Prewash” 

and “Dry Cleaning Fluid” are also proposed. As proposed, the definition of “Laundry 

Prewash” would be clarified to mean the product is used in a wet cleaning process. The 

modification to the “Dry Cleaning Fluid” definition would clarify that a dry cleaning fluid is 

a product used in only dry cleaning machines or by businesses that clean fabrics such 

as draperies at the customer’s residence. 

B. Proposed Amendments to Section 94509: Standards for 

Consumer Products 

We are proposing to amend the Table of Standards contained in section 94509(a) as 

well as several other requirements in section 94509. These proposals are described 

below. 
Technical Support Document Chapter VI - 47 

 1. Proposed Amendments to Section 94509(a) - Table of Standards 

The proposed regulatory action would amend the existing Consumer Products 

Regulation by specifying new or lower VOC limits for the product categories shown in 

Table VI-2. Together, VOC limits are proposed for 11 categories with 15 VOC limits. 

Special Purpose Lubricants are not currently regulated, while all of the other categories 

are currently subject to VOC limits. However, in the case of “Spot Remover” and “Oven 

or Grill Cleaner,” additional products are proposed for inclusion. For all but one of the 

currently regulated categories we are proposing lower VOC limits. We are proposing to 

slightly increase the current limit for nonaerosol “Oven or Grill Cleaner.” This proposal 

is explained further below. 

Table VI-2 also displays the proposed effective date for each proposed limit. As 

specified by the regulation, the effective date for products requiring Federal Insecticide, 

Fungicide, and Rodenticide Act (FIFRA) registration would be one year after the 

effective date shown here to allow for the registration process. Where appropriate, we 

are proposing separate limits for aerosol products to ensure feasibility. All of these 

proposed limits would be reflected in the Table of Standards in section 94509(a). 

Although not shown in Table VI-2, we are also proposing to delete the phrase “Non-FDA 

regulated” from the category “Astringent/Toner.” This phrase is not necessary because 

the category definition clearly specifies the types of products that are regulated as 

“Astringent/Toner” products. Other minor amendments to the Table of Standards are 

proposed to provide consistency or delete redundant language. 

The emission reductions from categories with limits becoming effective by 

January 1, 2014, would be creditable toward the current State Implementation Plan 

(SIP) commitment, and would result in VOC emission reductions of about 6.7 tons per 

day. Products in the categories that require FIFRA registration are provided an 

additional year beyond the effective date shown in Table VI-2. Because of this, the 

reductions from Flying Bug Insecticide and Wasp or Hornet Insecticide would be 

credited toward a future SIP commitment. Reductions from these two categories total 

about 0.2 tons per day. 

Several of the proposed VOC limits for the categories listed in Table VI-2 warrant 

additional explanation. 

Proposal for “Oven or Grill Cleaner”

We are proposing to incorporate grill cleaning products into the Oven Cleaner Category. 

To allow the previously unregulated grill cleaner products the necessary time to 

reformulate, proposed subsection 94509(q) would specify that the VOC limits do not 

apply to these products until December 31, 2012. 
Technical Support Document Chapter VI - 48 

Table VI-2 

Proposed VOC Limits by Product Form and Effective Dates 

Product Category Product Form 

Proposed VOC 

Limit 

(weight percent) Effective Date 

Flying Bug Insecticide Aerosol 20 12/31/2013* 

Furniture Maintenance Product Aerosol 12 12/31/2013 

General Purpose Cleaner Nonaerosol 0.5 12/31/2012* 

General Purpose Degreaser Nonaerosol 0.5 12/31/2012 

Glass Cleaner Nonaerosol 3 12/31/2012 

Heavy-duty Hand Cleaner or Soap Nonaerosol 1 12/31/2013 

Metal Polish or Cleanser Aerosol 15 12/31/2012 

Metal Polish or Cleanser Nonaerosol 3 12/31/2012 

Oven or Grill Cleaner Aerosol 8 12/31/2012** 

Oven or Grill Cleaner Nonaerosol 4 [Effective Date]** 

Special-purpose Lubricant Aerosol 25 12/31/2012 

Special-purpose Lubricant Nonaerosol 3 12/31/2012 

Spot Remover (Dry Clean Only) Aerosol 15 12/31/2012 

Spot Remover (Dry Clean Only) Nonaerosol 3 12/31/2012 

Wasp or Hornet Insecticide Aerosol 10 12/31/2013* 

* Products subject to FIFRA registration given an extra year to complete the registration process. 

** Only products being proposed for addition to the category have until 12/31/2012 to comply (see new 

 proposed subsection 94509(q)). 

Nonaerosol Oven Cleaner products are currently subject to a VOC limit of 

1 percent by weight. When this limit was adopted reported products relied on low or 

non-VOC caustic technologies. We have since learned of technologies that provide 

alternatives to caustic products. To accommodate the use of these technologies we are 

proposing to increase the current VOC limit to 4 percent by weight for nonaerosol Oven 

or Grill Cleaner products. To expedite allowing use of alternatives, as proposed, the 

limit revision would become effective when the amendments become legally effective. 

This proposal results in a small shortfall of about 0.1 tons per day. However, other 

reductions from this proposal would offset this change. We believe allowing for these 

less harsh alternatives outweighs the small VOC increase that would result. 

Proposal for “Spot Remover”

We are proposing to incorporate spotters used for dry clean only fabrics into the 

currently regulated “Spot Remover” category. These are primarily those products used 

at dry cleaning operations. To accommodate the necessary time for these products to 

reformulate, we are also proposing to delay the effective date of the VOC limit for “Spot 
Technical Support Document Chapter VI - 49 

Remover” products from December 31, 2010, to December 31, 2012. This modification 

is proposed to allow adequate time for reformulation of the new products being included 

in the category. The proposal to extend the effective date is intended to simplify 

enforcement activities related to this category; it would be difficult to discern the 

difference between the newly added products and those currently regulated. The 

proposal would result in delaying about a 0.25 tons per day VOC reduction for two 

years. Even with this proposed delay, the reductions would occur within the timeframe 

necessary to be creditable to the 2007 SIP. The newly added products would also be 

subject to the existing prohibition on the use of methylene chloride, perchloroethylene, 

and trichloroethylene for Spot Remover products effective December 31, 2012. 

2. Proposed Modifications to Subsections 94509 (i)(3), (m), (n), (o), (p), 

(q), (r), (t), and (u) 

Requirements Limiting the Use of Specific Toxic Compounds in Specific 

Consumer Products Categories

Currently, subsections 94509 (i)(3), (m), (n), (p), (q), and (u) specify provisions 

prohibiting use of the chlorinated toxic air contaminants methylene chloride, 

perchloroethylene, and trichloroethylene in specified categories. Subsection 94509(r) 

specifies prohibitions on the use of methylene chloride and perchloroethylene in 

Pressurized Gas Duster products. A prohibition on the use of para-dichlorobenzene in 

Solid Air Fresheners and Toilet/Urinal Care products is specified in subsection 

94509(o). Each of these subsections also has provisions that specify sell-through dates 

and exemptions for impurities (except no exemption for impurities is provided for paradichlorobenzene). The provisions are all similar except for effective and sell-through 

dates. We are proposing to consolidate these provisions into tables in proposed 

modified subsection 94509(m). The modifications are proposed to simplify the 

regulation by making it easier to find the prohibitions on toxic compounds. 

As proposed, subsection 94509(m)(1) would contain a new table, Table 94509(m)(1), 

that would list categories, effective dates, and sell-through dates for all categories 

where use of methylene chloride, perchloroethylene, and trichloroethylene is prohibited. 

A reference within the table is proposed to clarify that there are additional requirements 

for products defined as Brake Cleaner, Carburetor or Fuel Injection Air Intake Cleaner, 

Engine Degreaser, and General Purpose Degreaser - intended for use in automotive 

products. These products are also subject to the Airborne Toxic Control Measure for 

Emissions of Chlorinated Toxic Air Contaminants from Automotive Maintenance and 

Repair Activities, section 93111, title 17, California Code of Regulations. 

New Table 94509(m)(1) also contains proposed prohibitions on use of methylene 

chloride, perchloroethylene, and trichloroethylene in “Metal Polish or Cleanser,” 

“Silicone-based Multi-purpose Lubricant,” and “Special-purpose Lubricant.” These 

prohibitions are proposed to ensure that use of these toxic air contaminants does not 

occur as products are reformulated to meet the proposed VOC limits. These 

prohibitions are proposed as a mitigation measure under the California Environmental 
Technical Support Document Chapter VI - 50 

Quality Act (CEQA). The rationale for the prohibition is further explained in Chapter IX, 

Environmental Impacts, section E. The new table would also reflect that the effective 

date for “Spot Remover” products would be extended to December 31, 2012, to 

harmonize with the proposed modification of the effective date of the VOC limit. 

Although additional products are being added into the “Oven or Grill Cleaner” category, 

we are not proposing to extend the date the prohibition on use of methylene chloride, 

perchloroethylene, and trichloroethylene becomes effective. This is feasible because 

the products being added into the category do not currently use these compounds. 

Proposed subsection 94509(m)(2) would contain a new table, Table 94509(m)(2), that 

would list the categories effective dates, and sell-through dates for all categories where 

use of para-dichlorobenzene is prohibited. 

Requirements Limiting the Use of Alkylphenol Ethoxylate Surfactants in Specific 

Consumer Product Categories 

Staff is also proposing to prohibit the use of alkylphenol ethoxylate surfactants in 

several categories as a CEQA mitigation measure. Alkylphenol ethoxylates are 

nonionic surface active agents (surfactants) used as wetting agents, emulsifiers, and 

dispersants in cleaning and degreasing products. One reformulation pathway to meet 

proposed VOC limits would be to replace VOC solvents with surfactants. Alkylphenol 

ethoxylates meet the definition of LVP-VOC so their use is not currently restricted by the 

VOC limits in the Consumer Products Regulation. In the cleaning/degreasing 

categories, because of how the products are used, some product is washed ‘down the 

drain.’ Once into wastewater, alkylphenol ethoxylates do not readily degrade and they 

and/or their degradation products enter aquatic environments through wastewater 

treatment facilities or storm water. 

Ample scientific evidence implicates the alkylphenol ethoxylates as toxic to aquatic 

species. Among other things, they are suspected hormone disruptors, with the primary 

concern focused on the estrogenic effects of their degradation products (David et. al, 

2009). Nonylphenol and octylphenol ethoxylates have been shown to mimic the 

hormone estrogen. In light of this, ARB staff consulted with staff of the State Water 

Resources Control Board (SWRCB) to determine if use or increased use of alkylphenol 

ethoxylates would pose an adverse impact on California’s receiving waters. 

Information provided to the SWRCB staff indicates that alkylphenol ethoxylates are 

found in measurable concentrations in the State’s receiving waters. Moreover, SWRCB 

staff is concerned that any potential increased use of alkylphenol ethoxylates could 

adversely impact aquatic species (SWRCB, 2010a; SWRCB, 2010b; SCCWRP, 2010; 

and SFEI, 2010). As proposed, after December 31, 2012, use of alkylphenol ethoxylate 

surfactants would be prohibited from use in Oven or Grill Cleaner products and in the 

nonaerosol forms of General Purpose Cleaner, General Purpose Degreaser, and Glass 

Cleaner. A proposed prohibition on use in nonaerosol Heavy-duty Hand Cleaner or 

Soap products would become effective December 31, 2013. These prohibitions are 

proposed to ensure that use of these compounds does not occur as products are 
Technical Support Document Chapter VI - 51 

reformulated to meet the proposed VOC limits. This proposal would be contained in 

modified subsection 94509(m)(3). 

Staff also finds that replacements for alkylphenol ethoxylates are readily available. 

Alcohol ethoxylate, linear alkylbenzene sulphonate, and alkyl polyglucoside 

surfactants are considered to be effective and environmentally safer. Additional 

information on this proposal is contained in Chapter IX, Environmental Impacts, 

section E. 

 Additional Modifications to subsection 94509(m)

Proposed new subparts 94509(m)(4) and (m)(5) would specify the provisions related to 

sell-through of products manufactured before the effective dates of the prohibitions. 

Proposed new subpart 94509(m)(6) would specify the exemption for impurities for the 

categories listed in Table (m)(1). 

Requirements for Specific Consumer Products Limiting the Use of Any Chemical 

Compound that has a Global Warming Potential (GWP) Value of 150 or Greater

At present, subsections 94509(r), (t), and (q), among other things, contain prohibitions 

on the use of compounds that have GWP values of 150 or greater. We are proposing to 

consolidate these provisions into modified subsection 94509(n). New Table 94509(n)(1) 

would list the categories, effective date, and sell-through date for each category where 

GWP limits have been adopted. Newly proposed Table 94509(n)(1) would also include 

additional categories for which we are proposing GWP limits in this rulemaking. We are 

proposing to prohibit the use of global warming compounds that have GWP values of 

150 or greater in “Flying Bug Insecticide,” “Furniture Maintenance Product,” “Metal 

Polish or Cleanser,” “Special-purpose Lubricant,” “Spot Remover,” and “Wasp or Hornet 

Insecticide” products. These prohibitions are proposed to ensure that use of 

compounds with higher GWP values does not begin as products are reformulated to 

meet proposed VOC limits. The measure is proposed as a CEQA mitigation measure 

and the rationale for the prohibition is further explained in Chapter IX, Environmental 

Impacts, section E. 

New subparts (n)(2) and (3) would specify the provision related to sell-through. New 

subpart (n)(4) would specify the exemption for impurities. The modifications are 

proposed to simplify the regulation by making it easier to find the prohibitions on use of 

compounds with GWP values of 150 or greater. 

Additional Modifications to Section 94509

Because of the consolidation of various provisions into new subsections 94509(m) and 

(n), as described above, we are proposing to delete existing subparts (i)(3), (m), (n), (o), 

(p), (q), (r), and (t). Subsection (s) would be re-lettered to subsection (o). Subsection 

(u) would be re-lettered to subsection (p) and be modified to pertain only to provisions 

related to limiting the aromatic compound content of Paint Thinner and Multi-purpose 
Technical Support Document Chapter VI - 52 

Solvent products. The references within the Table of Standards in section 94509(a) to 

the various toxic compound prohibitions and the GWP limits would also be modified to 

reference new subsections (m) and (n), as well as the re-lettered subsections (o) 

and (p). 

Proposed new subsection 94509(q) would specify the compliance date for new products 

added to the “Oven or Grill Cleaner” category. As proposed, the effective date for the 

newly added products would be December 31, 2012. This should allow adequate time 

for the noncomplying products to reformulate. 

C. Proposed Amendments to Sections 94510: Exemptions and 

Section 94515: Test Methods 

Minor amendments are proposed to sections 94510 and 94515. The amendments to 

subsection (c) would delete unnecessary language. Amendment to subsection (g) is 

proposed to reference new subsection (m)(2) relating to prohibitions on use of 

para-dichlorobenzene. 

Minor modifications are proposed to subsections 94515 (c) and (d) to reflect the 

reorganization of subsection 94509 (m) and (n). Sections (c) and (d) specify 

procedures related to determining the aromatic compound content of Paint Thinner and 

Multi-purpose Solvent products. 

D. Proposed Amendments to Section 94512: Administrative 

Requirements 

We are proposing to amend the Most Restrictive Limit provision contained in 

subsection 94512(a). Subpart (3) would be modified to clarify the regulation’s 

applicability when two defined categories exclude each other within their respective 

definitions. As proposed, when a definition for a specific category excludes another 

specific category and vice versa, the product is subject to the VOC limit for whichever 

category is lower. 

E. Proposed Amendments to Method 310 

ARB Test Method 310 sets forth the analytical procedures and processes to determine 

the VOC content of consumer products. We are proposing to amend this method to 

incorporate additional testing procedures and standard test methods to analyze 

consumer products for compliance. These modifications are proposed to specify the 

procedures to be used to analyze for the aromatic compound content in “Paint Thinner” 

and “Multi-purpose Solvent” products and the VOC content of “Fabric Softener-Single 

Use Dryer Product.” 

Proposed amendments to section 2 of Method 310 would include additional applicable 

test methods to analyze consumer products for compliance. The added methods would 
Technical Support Document Chapter VI - 53 

pertain to analysis of aromatic compound content. The following methods are proposed 

for addition: 

• ASTM D 3257-06: Standard Test Methods for Aromatics in Mineral Spirits by 

Gas Chromatography (April 1, 2006) 

• ASTM D 3606-07: Standard Test Method for Determination of Benzene and 

Toluene in Finished Motor and Aviation Gasoline by Gas Chromatography (Nov. 

1, 2007) 

• ASTM D 3710-95 (Reapproved 2004): Standard Test Method for Boiling Range 

Distribution of Gasoline and Gasoline Fractions by Gas Chromatography (Nov. 1, 

2004) 

• ASTM D 5443-04: Standard Test Method for Paraffin, Naphthene, and Aromatic 

Hydrocarbon Type Analysis in Petroleum Distillates Through 200° C by MultiDimensional Gas Chromatography (Nov. 1, 2004) 

• ASTM D 5580-02 (Reapproved in 2007): Standard Test Method for 

Determination of Benzene, Toluene, Ethylbenzene, p/m-Xylene, o-Xylene, C9

and Heavier Aromatics, and Total Aromatics in Finished Gasoline by Gas 

Chromatography (Nov. 1, 2007) 

• ASTM E 1782-08: Standard Test Method for Determining Vapor Pressure by 

Thermal Analysis (March 1, 2008) 

• U.S. EPA Method 602: Purgable Aromatics, 40CFR Part 136 Appendix A, 

Method for Organic Chemical Analysis of Municipal and Industrial Wastewater 

(January 2008) 

• U.S. EPA Method 625: Base/Neutrals and Acids, 40CFR Part 136 Appendix A, 

Method for Organic Chemical Analysis of Municipal and Industrial Wastewater 

(January 2008) 

• U.S. EPA SW-846 Method 8015B: Nonhalogenated Organics Using GC/FID (Rev 

2, December 1996) 

• U.S. EPA SW-846 Method 8020A: Aromatic Volatile Organics by Gas 

Chromatography (Rev 1, September 1994) 

• U.S. EPA SW-846 Method 8270D: Semivolatile Organic Compounds by Gas 

Chromatography / Mass Spectroscopy (GC/MS) (Rev. 4, January 1998) 

New subsections are also being proposed. Proposed new subsection 3.3.8 would 

specify the procedures for analyzing for aromatic compound content in “Paint Thinner” 

and “Multi-purpose Solvent” products. New subsection 4.2.3 would specify the 
Technical Support Document Chapter VI - 54 

procedures for analyzing for the VOC content of “Fabric Softener-Single Use Dryer 

Product.” 

REFERENCES 

1. Air Resources Board. Initial Statement of Reasons, Proposed Amendments to 

the California Consumer Products Regulations. August 7, 2009. (ARB, 2009c) 

2. Air Resources Board. Initial Statement of Reasons for Proposed Rulemaking 

Proposed Amendments to the California Consumer Products Regulation. 

 May 9, 2008. (ARB, 2008a) 

3. Air Resources Board. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation and the Aerosol Coatings 

Regulation. September 29, 2006. (ARB, 2006a) 

4. Air Resources Board. Initial Statement of Reasons for the Proposed 

Amendments to the California Aerosol Coating Products, Antiperspirants and 

Deodorants, and Consumer Products Regulations, Test Method 310, and 

Airborne Toxic Control Measure for para-Dichlorobenzene Solid Air Fresheners 

and Toilet/Urinal Care Products. May 7, 2004. (ARB, 2004b) 

5. Air Resources Board. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation: Midterm Measures II. 

 September 10, 1999. (ARB, 1999) 

6. Air Resources Board. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation: Midterm Measures I. 

 June 6, 1997. (ARB, 1997b) 

7. Air Resources Board. Proposed Amendments to the Statewide Regulation to 

Reduce Volatile Organic Compound Emissions from Consumer Products –

Phase II – Staff Report. October, 1991. (ARB, 1991) 

8. Air Resources Board. Proposed Regulation to Reduce Volatile Organic 

Compound Emissions from Consumer Products – Staff Report. 

 August, 1990. (ARB, 1990) 

9. David, A., Fenet, H., Gomez, E. Alkylphenols in Marine Environments: 

Distribution Monitoring Strategies and Detection Considerations. 2009. Marine 

Pollution Bulletin. Volume 58: 953-960. (David et al., 2009) 

10. San Francisco Estuary Institute. Occurrence of Alkylphenol Ethoxylate 

Surfactants in San Francisco Bay and Potential Impacts on Water Quality. 

Memorandum dated July 13, 2010, from Rainer Hoenicke, Ph.D., Executive 
Technical Support Document Chapter VI - 55 

Director, San Francisco Estuary Institute, to Darrin Polhemus, Deputy Director, 

Division of Water Quality, State Water Resources Control Board. (SFEI, 2010) 

11. Southern California Coastal Water Research Project. Effects on Water Quality of

Alkylphenol Ethoxylate Surfactants (APEOs). Memorandum dated July 15, 2010, 

from Keith Maruya, Principle Scientist, Southern California Coastal Water 

Research Project, to Darrin Polhemus, Deputy Director, Division of Water 

Quality, State Water Resources Control Board. (SCCWRP, 2010) 

12. State Water Resources Control Board. Water Quality Effects of Alkylphenol 

Ethoxylate Surfactants. Memorandum dated September 20, 2010, from Darrin 

Polhemus, Deputy Director, Division of Water Quality, State Water Resources 

Control Board, to Richard Corey, Chief, Stationary Source Division, Air 

Resources Board. (SWRCB, 2010a) 

13. State Water Resources Control Board. Effects on Water Quality of Alkylphenol 

Ethoxylate Surfactants. Memorandum dated July 19, 2010, from Valerie Connor, 

Ph.D., Deputy Director, Office of Information Management and Analysis, State 

Water Resources Control Board, to Darrin Polhemus, Deputy Director, Division of 

Water Quality, State Water Resources Control Board. (SWRCB, 2010b)
Technical Support Document Intentionally Blank Page - 56 
Technical Support Document Chapter VII - 57 

Chapter VII. Description of Product Categories 

In this chapter, we describe each product category and provide the technical basis for 

the proposed requirements. We are proposing volatile organic compound (VOC) limits 

for 11 categories. In several categories, prohibitions on use of specific toxic air 

contaminants (TAC), green house gas (GHG) compounds with higher global warming 

potential (GWP) values, and alkylphenol ethoxylate surfactants are proposed. These 

three prohibitions are proposed in accordance with the California Environmental Quality 

Act (CEQA). If applicable, proposed modifications to definitions are provided along with 

the rationale for the changes. 

In each section below, two tables of data are provided. Unless otherwise indicated, the 

data in the tables are based on the 2006 Consumer and Commercial Products Survey 

(2006 Survey). The data have been grown to the current calendar year, 2010, based on 

population increases. In addition, in each category it is assumed that the 2006 Survey 

contains information for about 90 percent of the products sold into California. 

Therefore, the data in the tables are adjusted for market coverage. The VOC emission 

reductions predicted are also grown to the calendar year the proposed limits would 

become effective, based on projected population increases. In one category, “Spot 

Remover” (Dry Clean Only), the data are based on the 2008 Survey Update for Dry 

Clean Only Spot Removers (2008 Survey Update). The surveys are described in 

greater detail in Chapter V. 

A. Flying Bug Insecticide (aerosol)

Flying Bug Insecticide products are designed to be used primarily by consumers in the 

control of flying household insects or pests such as flies, mosquitoes, gnats, and moths. 

Flying Bug Insecticide products do not include “Wasp or Hornet Insecticide,” products 

designed to be used on humans or animals, or any moth-proofing product. 

All insecticides sold within California must be registered with the California Department 

of Pesticide Regulation (DPR) and with the U.S. EPA under the Federal Insecticide, 

Fungicide, and Rodenticide Act (FIFRA). These registrations are designed to 

thoroughly evaluate the insecticide product to ensure it meets both federal and State 

requirements to protect public health and the environment. As part of the registration 

process, the efficacy data are reviewed to validate the spectrum of activity. For 

products registered under FIFRA, as specified in section 94509(d), the Consumer 

Products Regulation allows an additional year for compliance with the VOC limit to allow 

the necessary time to complete the registrations. 
Technical Support Document Chapter VII - 58 

Flying Bug Insecticide products were first regulated as part of the Phase-II amendments 

approved by the Board in January 1992. At that time, the Board approved a 35 percent 

by weight VOC limit for all forms, effective January 1, 1995. In 1999, the VOC limit for 

aerosol Flying Bug Insecticide products was lowered to 25 percent by weight, effective 

December 31, 2003. Additional information on product use and marketing can be found 

in the 1991 Phase-II and the 1999 Midterm Measures II “staff reports” (ARB, 1991; ARB 

1999). 

The 2006 Survey data provide the basis for our determination that it is both 

technologically and commercially feasible to further reduce the VOC content of Flying 

Bug Insecticide products. Based on these data, staff is proposing to lower the VOC limit 

for aerosol products to 20 percent by weight. 

Table VII-1 below summarizes the sales and emissions from aerosol Flying Bug 

Insecticide products based on the results of the 2006 Survey (ARB, 2007e). The data 

for the 51 reported products have been grown, by population, to 2010. Total category 

sales from these products are about 5,858 pounds per day. 

Table VII-1 

Flying Bug Insecticide 

Product Form 

Number of 

Products 

2010 

Category Sales 

(pounds per day) 

2010 Market-Adjusted 

VOC Emissions 

(pounds per day) 

Aerosol 51 5,858 1,306 

Also shown in Table VII-1, estimated 2010 market-adjusted VOC emissions for aerosol 

Flying Bug Insecticide products are 1,306 pounds per day, or about 0.7 tons per day in 

California. Although not shown, the sales-weighted average VOC content is about 

22 percent by weight. 

Product Use and Marketing: 

Flying Bug Insecticide products are used primarily by household consumers and 

janitors. These products may be used either indoors or outdoors and in multiple 

settings including households, businesses, and institutions. Flying Bug Insecticide 

products also include some foggers designed to release contents, as a fog or mist, in 

outdoor areas to control flying insects. 

Flying Bug Insecticide products are typically sold in supermarkets; general mass market 

stores; discount stores; home improvement stores; and nurseries. 

Product Formulation: 

Flying Bug Insecticide products contain both "active" and "inert" ingredients. The terms 

"active ingredient" and "inert ingredient" have been defined by the U.S. EPA. An active 
Technical Support Document Chapter VII - 59 

ingredient prevents, destroys, repels or mitigates a pest, or is a plant regulator, 

defoliant, desiccant or nitrogen stabilizer. By law, the name and percent by weight of 

the active ingredient must be identified and displayed on the product label. 

An inert ingredient is defined by U.S. EPA as any substance (or group of structurally 

similar substances if designated by U.S. EPA), other than an active ingredient, which is 

intentionally included in a pesticide product. Inert ingredients may play a key role in the 

effectiveness of a pesticide product. For example, inert ingredients may serve as a 

solvent, or may extend the pesticide product's shelf-life. Pesticide products can contain 

many inert ingredients, but federal law does not require that these ingredients be 

identified by name or percentage on the label. Only the total percentage of inert 

ingredients is required to be on the pesticide product label (U.S. EPA, 2003b; 

U.S. EPA, 2010a). 

In this rulemaking, our proposal does not directly affect the active ingredients to be 

used. The proposal affects the inert ingredients that are VOCs and compounds with 

higher GWP values. 

The VOC content of aerosol Flying Bug Insecticide products ranges from 

0 to 25 percent by weight. Flying Bug Insecticide products typically contain about 

1 percent pyrethrins and/or pyrethroids as the active ingredient (ARB, 2007e). 

Pyrethrins are derived from Chrysanthemum flowers and pyrethroids are synthetic 

derivatives of pyrethrins. Some commonly used pyrethroids in Flying Bug Insecticide 

products include permethrin, tetramethrin, allethrin, and resmethrin. These active 

ingredients perform the key function of the insecticide which is to either kill or inhibit the 

targeted pest. Most active ingredients qualify as low vapor pressure (LVP) VOCs, 

therefore the proposed VOC limit would not apply to these compounds. 

Based on data received from the 2006 Survey, most products in this category are waterbased and use a hydrocarbon propellant to evacuate the contents. Hydrocarbon 

propellants are the primary source of VOCs in these products and the propellants 

comprise up to about 25 percent by weight of the product. A small amount of LVP-VOC 

surfactant is often added to emulsify the active ingredients with water. Together, these 

are the inert ingredients. 

Proposed VOC Limit and Compliance: 

The proposed VOC limit for aerosol Flying Bug Insecticide products is 20 percent by 

weight, effective December 31, 2013. As shown in Table VII-2, using adjusted 

emissions, the proposed 20 percent limit will result in an estimated VOC emission 

reduction of 115 pounds per day, or about 0.06 tons per day, in 2014. The emission 

reduction is estimated for 2014 because to complete the registration process required 

by FIFRA and the DPR the Consumer Products Regulation allows an extra year to 

complete this process. This reduction, although important to overall air quality, will not 

occur within the timeframe to be credited toward the current SIP commitment. 
Technical Support Document Chapter VII - 60 

Table VII-2 

Flying Bug Insecticide Proposal 

Product Form

Proposed 

VOC Limit 

(weight percent) 

Number of

Complying 

Products 

Complying 

Market Share 

(percent)

2014 Emissions 

Reductions 

(pounds per day) 

Aerosol 20 18 55 115 

As shown in Table VII-2, 18 products, representing approximately 55 percent of the 

market, currently comply with the proposed VOC limit of 20 percent by weight. Thus, 

staff has determined that reformulation to the proposed limit is both technologically and 

commercially feasible. 

In determining the most feasible limit staff reviewed data indicating that aerosol Flying 

Bug Insecticides require about 20 percent VOC propellant. This amount is necessary to 

achieve the appropriate particle size to remain suspended in the air for an adequate 

amount of time to directly contact the flying insect. Effective particle size is 

approximately 30-50 micrometers in diameter (AgrEvo, 2010). The data also indicated 

that as the level of propellant decreases, particle size increases (MGK, 2010). When 

the amount of propellant was reduced to less than 20 percent particles greater than 

60 micrometers in diameter were dispersed. These are too large to maintain product 

efficacy. Further, these data demonstrate the continued validity of a statement staff 

made in the “Midterm Measures II” staff report: “Particle size is a key difference 

between crawling and flying bug killers, and is generally related to the amount of 

propellant in the formulation” (ARB, 1999). Flying Bug Insecticide product 

manufacturers also identified 20 percent VOC as the lowest possible limit that would 

maintain product efficacy (CSPA, 2010a). 

Reformulation options that can be used by manufacturers to meet the proposed limit 

include reducing the level of hydrocarbon propellant and increasing the amount of 

water, and/or LVP-VOC distillate. We expect that manufacturers will meet the proposed 

limit by using formulation technologies similar to those already used in complying 

products. 

Proposed Global Warming Potential (GWP) Limit: 

No compounds with GWP values at or above 150 were reported in the 2006 Survey for 

this category. However, to ensure that use of compounds with higher GWP values does 

not begin as products reformulate to comply with the proposed 20 percent by weight 

VOC limit, we are proposing a GWP limit of 150 for any chemical compound used in 

Flying Bug Insecticide products, effective December 31, 2013. While this proposal 

would allow use of the non-VOC propellant, HFC-152a, we believe other reformulation 

options are more likely. The proposed limit would not apply to any chemicals present as 

contaminants, which in aggregate are 0.1 percent by weight or less. This limit is 

proposed as a mitigation measure under CEQA (see Chapter IX, Environmental 

Impacts, section E). The proposed GWP limit is contained in section 94509(n). 
Technical Support Document Chapter VII - 61 

B. Furniture Maintenance Product (aerosol)

“Furniture Maintenance Product” is defined as a product designed or labeled to wax, 

polish, protect, or enhance a previously finished wood surface by leaving a protective 

finish that is designed to be periodically replenished. Products designed for use on 

wood floors are not included. These products may also be used on other furniture 

surfaces, such as acrylics, ceramic, plastics, stone, metal, and fiberglass. This category 

does not include “Dusting Aid,” “Wood Cleaner,” and products designed solely for the 

purpose of cleaning. Products designed to leave a permanent finish such as stains, 

sanding sealers, and lacquers are also excluded. Products that are designed with the 

sole purpose of removing dust without leaving a protective finish are regulated as 

“Dusting Aid.” While the “Furniture Maintenance Product” category includes products 

that claim to clean and polish wood surfaces, products that are designed solely to clean 

a wood surface are regulated as “Wood Cleaners.” 

Aerosol Furniture Maintenance Products are currently subject to a 17 percent by weight 

VOC limit, which has been in effect since December 31, 2004. 

The 2006 Survey data provides the basis for our determination that it is both 

technologically and commercially feasible to further reduce the VOC content of these 

products. Based on these data, staff is proposing to lower the VOC limit for aerosol 

Furniture Maintenance Products to 12 percent by weight. 

Table VII-3 below summarizes the sales and emissions from aerosol Furniture 

Maintenance Products based on the results of the 2006 Survey (ARB, 2007e). The 

data for the 87 reported products have been grown, by population, to 2010. Total 

category sales from these products are about 16,792 pounds per day. 

Table VII-3 

Furniture Maintenance Product 

Product Form 

Number of 

Products 

2010 

Category Sales 

(pounds per day) 

2010 Market-Adjusted 

VOC Emissions 

(pounds per day) 

Aerosol 87 16,792 2,640 

Also shown in Table VII-3, estimated 2010 market-adjusted VOC emissions for aerosol 

Furniture Maintenance Products are 2,640 pounds per day, or about 1.3 tons per day in 

California. Although not shown, the sales-weighted average VOC content is about 

15.7 percent by weight. 

Product Use and Marketing: 

Aerosol Furniture Maintenance Products are used by household, institutional, and 

industrial users. Many of these products are designed for use on a variety of wood 

surfaces. In addition, there are a number of aerosol Furniture Maintenance Products 
Technical Support Document Chapter VII - 62 

that are designed for use on other furniture surfaces such as ceramic, plastic, stone, 

metal, and fiberglass. Aerosol Furniture Maintenance Products are designed to be 

sprayed either directly on a furniture surface and wiped with a clean cloth, or sprayed 

directly onto a clean cloth which is then used to wipe a surface. Aerosol Furniture 

Maintenance Products that contain silicone oils are often labeled with the claim 

“increases shine without leaving a waxy residue.” 

Aerosol Furniture Maintenance Products are primarily sold to the household consumer 

through retail outlets such as supermarkets, grocery stores, and warehouse stores. 

Products sold to institutional and industrial users are supplied though a variety of 

locations, including direct sales, catalog sales, janitorial stores, and the Internet. 

Product Formulation: 

Aerosol Furniture Maintenance Products are emulsions that typically contain water; a 

VOC hydrocarbon solvent; a VOC hydrocarbon propellant; and a polishing component 

such as silicone oil, mineral oil, or wax. The VOC hydrocarbon solvent constitutes up to 

about 7 percent of the product. The solvent functions to suspend the wax or oil and 

assists to remove smudges and fingerprint oils. The main polishing compounds 

reported are the exempt VOC volatile methylated siloxanes (VMS). VMS content of 

aerosol Furniture Maintenance Products ranges from 2 to 8 percent by weight. Another 

common polishing component found in these products is an LVP-VOC mineral oil. The 

hydrocarbon propellant which serves to expel the product ranges from about 

4 to12 percent by weight. These products may also contain a small amount of 

fragrance, such as citrus oils (ARB, 2007e). 

Proposed VOC limit and Compliance: 

The proposed VOC limit for aerosol Furniture Maintenance Products is 12 percent by 

weight, effective December 31, 2013. As shown in Table VII-4, using adjusted 2006 

emissions, the proposed VOC limit will result in an estimated emission reduction of 

724 pounds per day, or about 0.36 tons per day by 2013. 

Table VII-4 

Furniture Maintenance Product Proposal 

Product Form

Proposed VOC 

Limit 

(weight percent)

Number of

Complying 

Products

Complying 

Market Share 

(percent)

2013 Emissions 

Reductions 

(pounds per day) 

Aerosol 12 37 9.8 724 

As shown in Table VII-4, 37 of 87 reported products representing about 10 percent of 

product sales currently comply with the proposed 12 percent VOC limit. Therefore, staff 

has determined that the proposed VOC limit is technologically and commercially 

feasible. 
Technical Support Document Chapter VII - 63 

Complying products reported in the 2006 Survey contain an LVP-VOC solvent, a 

smaller percentage of hydrocarbon propellant, and mineral oil or VMS as the polishing 

agents. Reformulation options that can be used to meet the proposed limit include 

replacing all or part of the VOC hydrocarbon solvent by increasing use of LVP-VOC 

hydrocarbon solvent. Reducing the amount of hydrocarbon propellant also appears to 

be feasible, based on the 2006 Survey (ARB, 2007e). 

GWP Limit: 

No compounds with GWP values at or above 150 were reported in the 2006 Survey for 

this category. However, to ensure that use of compounds with higher GWP values does 

not begin as products reformulate to comply with the proposed 12 percent by weight 

VOC limit, we are proposing a GWP limit of 150 for any chemical compound used in 

Furniture Maintenance Products, effective December 31, 2013. While this proposal 

would allow use of the non-VOC propellant, HFC-152a, we believe other reformulation 

options are more likely. The proposed limit would not apply to any chemicals present as 

contaminants, which in aggregate are 0.1 percent by weight or less. This limit is 

proposed as a mitigation measure under CEQA (see Chapter IX, Environmental 

Impacts, section E). The proposed limit is contained in section 94509(n). 

Issues: 

1 Issue: Lowering the VOC limit in this category would open up the possibility of 

Wood Cleaner products being subject to the most restrictive limit (i.e. a product 

that is primarily a Wood Cleaner but whose label claims could be construed to 

also belong to the Furniture Maintenance Product). Such a product would have 

to meet the proposed 12 percent by weight VOC limit instead of the current 

17 percent by weight Wood Cleaner VOC limit. 

Response: Staff agrees that if a Wood Cleaner product makes claims that it is 

suitable for use as a Furniture Maintenance Product, the most restrictive limit 

provision applies and the product would need to contain no more than 12 percent 

VOC by weight. Therefore, it is incumbent on the responsible party to ensure 

that labeling claims are consistent only with the Wood Cleaner category. 

C. General Purpose Cleaner (nonaerosol) 

“General Purpose Cleaner” products are currently defined as a general purpose 

cleaning product labeled for use on a variety of hard surfaces, including small 

appliances. The General Purpose Cleaner category includes, but is not limited to, 

products designed or labeled for general floor cleaning, kitchen, countertop, or sink 

cleaning, and cleaners designed or labeled to be used on a variety of hard surfaces 

such as stovetops, cooktops, or microwaves. Because of its many uses, General 

Purpose Cleaner products are not subject to the Most Restrictive Limit provision in 

section 94512(a). Staff is proposing minor changes to the definition of “General 

Purpose Cleaner” to improve clarity. The proposed modified definition reads as follows: 
Technical Support Document Chapter VII - 64 

“General Purpose Cleaner” means a general purpose cleaning product labeled for use 

on to clean a variety of hard surfaces, including small appliances. “General Purpose 

Cleaner” includes, but is not limited to, products designed or labeled for general floor 

cleaning, kitchen, countertop, or sink cleaning, and cleaners designed or labeled to be 

used on a variety of hard surfaces such as stovetops, cooktops, or microwaves. 

Nonaerosol General Purpose Cleaner products are currently subject to a 

4 percent by weight VOC limit, which has been in effect since December 31, 2004. In 

addition, use of the TACs methylene chloride, perchloroethylene, and trichloroethylene 

is prohibited. This prohibition became effective December 31, 2008. 

The 2006 Survey data provides the basis for our determination that it is both 

technologically and commercially feasible to further reduce the VOC content of these 

products. Based on these data, in this rulemaking we are proposing to lower the VOC 

limit for nonaerosol General Purpose Cleaner products to 0.5 percent by weight. 

Table VII-5 below summarizes the sales and emissions from nonaerosol General 

Purpose Cleaner products based on the results of the 2006 Survey (ARB, 2007e). The 

data for the 1,518 reported products have been grown, by population, to 2010. Total 

category sales from these products are about 870,854 pounds per day. 

Also shown in Table VII-5, estimated 2010 market-adjusted VOC emissions for 

nonaerosol General Purpose Cleaner products are 24,078 pounds per day, or 

Table VII-5 

General Purpose Cleaner 

Product Form 

Number of 

Products 

2010 

Category Sales 

(pounds per day) 

2010 Market-Adjusted 

VOC Emissions 

(pounds per day) 

Nonaerosol 1,518 870,854 24,078 

about 12 tons per day in California. Although not shown in the table, the salesweighted average VOC content is 0.8 percent by weight. 

Based on data from the 2003 Survey (ARB, 2004a), aerosol General Purpose Cleaner 

products were found to have sales of about 6,800 pounds per day, or about 3.4 tons per 

day. This suggests that nonaerosol products dominate the market in this category. 

Product Use and Marketing: 

General Purpose Cleaner products are used by household and institutional consumers 

for general cleaning and removal of soils, stains, or spots from different hard surfaces 

such as floors, counters, and sinks. For cleaning, products are applied either directly to 
Technical Support Document Chapter VII - 65 

the surface or indirectly with a mop or sponge to cover large areas. Rinsing may or may 

not be necessary after the product is used. 

Nonaerosol General Purpose Cleaner products are sold either as concentrates or 

ready-to-use (RTU) products and are available with many different delivery systems, 

including liquids, solids, pump sprays, and wipes. Industrial and Institutional consumers 

might also use products in automated dispensing machines. Some products are 

marketed under the name of a specific active ingredient in their formulations such as 

citrus cleaner, pine cleaner, bleach cleaner, or ammoniated cleaner. Because of their 

degreasing and glass cleaning abilities, some of the products are also marketed as 

“cleaner-degreaser,” “all-purpose cleaner,” “glass and surface cleaner,” or “multi-surface 

cleaner.” There are also General Purpose Cleaner products that make anti-microbial 

claims. 

General Purpose Cleaner products are available in a variety of stores, including grocery 

stores, janitorial supply stores, discount stores, etc. They are sold to household 

consumers, janitors, restaurants, and other commercial or institutional establishments 

for general cleaning and, to a certain extent as an anti-microbial agent. For the purpose 

of this regulation, products primarily labeled as “General Purpose Cleaner” that make 

anti-microbial or disinfecting claims are considered “General Purpose Cleaner” 

products. 

Additional information on product use and marketing can be found in the “1999 Mid-term 

Measures II” and “2006 CONS-2” “Initial Statement of Reasons for the Proposed 

Amendments to the Consumer Products Regulation” (ARB, 1999; ARB, 2006a). 

Product Formulation: 

Nonaerosol General Purpose Cleaner products are primarily water-based products. In 

liquid products VOC ingredients are isopropyl and ethyl alcohols, ethylene glycol 

monobutyl ether, pinene, and d-limonene. The VOC content ranges from 0 to 4 percent 

by weight. LVP-VOCs reported include several glycol ethers and triethanolamine. 

Other ingredients reported include, surfactants, and inorganic compounds. The VOC 

and LVP-VOC glycol ethers, terpenes, and alcohols provide solvency to remove most 

soils. Inorganic compounds aid in maintaining pH and solvency. Ethanolamines are 

weak bases that can provide stability and texture to a product. Products generally 

contain a small amount of fragrance. Surfactants play a key role in the cleaning 

process. Their role is discussed below. 

Nonaerosol General Purpose Cleaner product formulations use a variety of wetting 

agents or surfactants. They reduce surface tension of liquids and assist in the cleaning 

of soils from multiple surfaces. Ionic surfactants are either anionic or cationic. Anionic 

surfactants are water soluble and have a negative charge in solution. They typically are 

‘foaming’ or ‘sudsy’ and are good cleaners. Examples include linear alkyl benzene 

sulfonate, soaps or fatty acid salts, and sodium dodecyl sulfate (CQ, 2008). Cationic 

surfactants are positively charged in aqueous solution. They are less effective cleaners. 
Technical Support Document Chapter VII - 66 

The primary cationic surfactants, are the quaternary ammonium compounds. These are 

the typical active ingredients in products making anti-microbial claims (PG, 2010). 

Nonionic surfactants are low sudsing and do not have a charge. Because they do not 

ionize in solution they are not affected by water hardness. They are good cleaning 

agents. Common nonionic surfactants include alcohol ethoxylates, alkyl 

polysaccharides, and alkylphenol ethoxylates. 

Nonaerosol General Purpose Cleaner products that make anti-microbial claims must be 

FIFRA and DPR registered. About 80 of the reported products are FIFRA registered 

products. Many anti-microbial General Purpose Cleaner products contain LVP-VOC 

quaternary ammonium compounds as the active ingredient. Other reported active antimicrobial ingredients include sodium hypochlorite (bleach) and l-lactic acid. These 

compounds did not have to be speciated in the survey, but we are aware that these are 

the active anti-microbial agents because of FIFRA labeling requirements. 

Health and Safety Code Section 41712(e)(1) directs the ARB to consider 

recommendations from a health agency (local, state, or federal) regarding regulation of 

health benefit products. This process was put in place to ensure that public health 

would not be compromised by regulating the VOC content of such products. Because 

anti-microbial nonaerosol General Purpose Cleaner products may be considered health 

benefit products, in accordance with the statute, staff consulted with the California 

Department of Public Health (DPH). DPH staff indicated that reducing the VOC content 

of General Purpose Cleaner products should not affect the ability of manufacturers to 

sell efficacious anti-microbial general purpose cleaning products (CA DPH, 2010). 

Proposed VOC Limit and Compliance: 

The proposed VOC limit for nonaerosol General Purpose Cleaner products is 

0.5 percent by weight, effective December 31, 2012. As shown in Table VII-6, using 

adjusted 2006 emissions, the proposed VOC limit will result in an estimated emission 

reduction of 7,460 pounds per day, or about 3.73 tons per day effective 

December 31, 2012. 

Table VII-6 

General Purpose Cleaner Proposal 

Product Form

Proposed 

VOC Limit 

(percent) 

Number of

Complying 

Products

Complying 

Market Share 

(percent)

2012 Emissions 

Reductions 

(pounds per day)

Nonaerosol 0.5 980 69 7,460 

Table VII-6 also shows that 980 products representing 69 percent of the market 

currently comply with the proposed limit. Data from the 2006 Survey also show 

complying products in each reported method of delivery. Although not shown, for 

FIFRA registered products, the complying market share is 73 percent. 
Technical Support Document Chapter VII - 67 

The 0.5 percent by weight VOC limit is proposed based on staff’s review of the data 

collected from the 2006 Survey as well as the review of existing technologies for use in 

cleaning applications. Reformulation options include the continued use of water along 

with various cleaning ingredients such as inorganic compounds (sulfates), LVP-VOC 

glycol ethers, triethanolamine, bleach, carbonates, ammonia, and surfactants. Because 

there are many viable low, and non-VOC alternatives available, as well as a high 

complying market share, we believe the proposed limit is commercially and 

technologically feasible. 

Proposal to Prohibit Use of Alkylphenol Ethoxylate Surfactants: 

Alkylphenol ethoxylate surfactants, in particular the octylphenol and nonylphenol 

ethoxylates, are known to be toxic to aquatic species. We are aware that some 

nonaerosol General Purpose Cleaner products contain these compounds. Because of 

this, ARB staff consulted with State Water Resources Control Board (SWRCB) staff to 

determine if continued use of these compounds could adversely affect water quality. 

Information provided to SWRCB staff indicates that alkylphenol ethoxylates were found 

in measurable concentrations in the State’s receiving waters. Therefore, SWRCB staff 

expressed concern that any potential increased use of alkylphenol ethoxylate 

surfactants could adversely impact aquatic species (SWRCB, 2010a; SWRCB, 2010b; 

SCCWRP, 2010; and SFEI, 2010). In light of this finding, we are proposing a CEQA 

mitigation measure to ensure that use of alkylphenol ethoxylate surfactants does not 

occur as products reformulate. As proposed, section 94509(m)(3) would preclude use 

of alkylphenol ethoxylate surfactants in General Purpose Cleaner (nonaerosol) products 

effective December 31, 2012. Further information on this proposal, as well as the need, 

is contained in Chapters VI and IX. 

Issues: 

1. Issue: The proposed VOC limit is not commercially and/or technologically 

feasible. 

Response: While working with stakeholders on this issue, staff thoroughly 

investigated the claim. At the request of stakeholders data were subdivided into 

all delivery mechanisms. Anti-microbial products were also evaluated. 

Complying products are available in every type of delivery system. Therefore, 

staff believes that the proposed VOC limit is technologically and commercially 

feasible. 

2. Issue: The proposed limit will negatively impact anti-microbial products. 

 

Response: Survey data have shown that anti-microbial products are available at 

or below the proposed limit. The complying market share for anti-microbial 

products is 73 percent. It should also be noted that the most commonly used 

active ingredients for these products are quaternary ammonium compounds, 
Technical Support Document Chapter VII - 68 

which are LVP-VOCs. DPH staff indicated that reducing the VOC content of 

General Purpose Cleaner products should not affect the ability of manufacturers 

to sell efficacious anti-microbial general purpose cleaning products 

(CA DPH, 2010). 

3. Issue: An exemption should be provided for products that use an integrated 

cleaning system. 

 

Response: The data show a high complying market share for General Purpose 

Cleaner products that perform similar tasks, i.e., floor cleaning. Therefore, staff 

concludes that an exemption for products that employ an integrated system is not 

warranted. The data clearly show that the basic market demand can be met. 

Providing an exemption for specific delivery mechanisms would unnecessarily 

diminish emission reductions. 

4. Issue: The proposed VOC limit is not feasible for ‘wipe’ products. 

Response: It is important to note that a ‘wipe’ product is a method to deliver a 

liquid product. The VOC limit is feasible for liquid products. 

D. General Purpose Degreaser (nonaerosol) 

General Purpose Degreaser products are products labeled to remove or dissolve 

grease, grime, oil and other oil-based contaminants from a variety of substrates, 

including automotive or miscellaneous metallic parts. The General Purpose Degreaser 

category currently does not include the other regulated categories “Engine Degreaser,” 

“General Purpose Cleaner,” “Adhesive Remover,” “Electronic Cleaner,” “Electrical 

Cleaner,” “Energized Electrical Cleaner,” or “Metal Polish or Cleanser.” Products used 

exclusively in solvent cleaning tanks or related equipment, such as cold cleaners, vapor 

degreasers, conveyorized degreasers, or film cleaning machines are not General 

Purpose Degreaser products. An additional exclusion is provided for industrial products 

that are (A) sold exclusively to establishments which manufacture or construct goods or 

commodities; and (B) are labeled “not for retail sale.” Products designed to clean 

miscellaneous metallic parts by immersion in a container are also excluded. 

Nonaerosol General Purpose Degreaser products are currently subject to a 

4 percent by weight VOC limit, which has been in effect since December 31, 2004. In 

addition, use of the TACs methylene chloride, perchloroethylene, and trichloroethylene 

is prohibited. This prohibition became effective December 31, 2005. 

The 2006 Survey provides the basis for our determination that it is commercially and 

technologically feasible to further reduce the VOC content of these products. Based on 

these data, staff is proposing to lower the VOC limit for nonaerosol products to 

0.5 percent by weight. Modifications to the definition are also proposed. 
Technical Support Document Chapter VII - 69 

We are proposing to amend the General Purpose Degreaser definition to clarify the 

exemption for products used at manufacturing facilities. At present the definition 

excludes products that are sold exclusively to facilities that manufacture or construct 

goods or commodities, and that are labeled “not for retail sale.” We have determined 

that the phrase “not for retail sale” is inadequate to describe these products used in the 

manufacturing process and that use of this term could allow for unintended products to 

meet this exemption criterion. We have also determined that in the normal chain of 

commerce, responsible parties for General Purpose Degreaser products sell products to 

distributors, who in turn, sell to manufacturing facilities. With this understanding, we are 

proposing to amend the exclusion to also allow distributors to sell directly to 

manufacturing facilities. To ensure that only products used in the manufacturing 

process itself meet the exclusion, we are proposing that these products must be labeled 

“For Manufacturing Use Only.” The phrase “not for retail sale,” for the purpose of this 

regulation, would be deleted. As proposed, this provision would become effective at the 

end of 2012. Until that time the current definition would remain in effect. 

On or after December 31, 2012, a “General Purpose Degreaser” would be defined as: 

any product labeled to remove or dissolve grease, grime, oil and other oil-based 

contaminants from a variety of substrates, including automotive or miscellaneous 

metallic parts. “General Purpose Degreaser” does not include “Adhesive Remover,” 

“Electrical Cleaner,” “Electronic Cleaner,” “Energized Electrical Cleaner,” “Engine 

Degreaser,” “General Purpose Cleaner,” “Metal Polish or Cleanser,” or “Oven or Grill 

Cleaner.” “General Purpose Degreaser” also does not include products used 

exclusively in “solvent cleaning tanks or related equipment,” or products that are (A) 

exclusively sold directly or through distributors to establishments which manufacture or 

construct goods or commodities; and (B) labeled exclusively for "use in the 

manufacturing process only." “Solvent cleaning tanks or related equipment” includes, 

but is not limited to, cold cleaners, vapor degreasers, conveyorized degreasers, film 

cleaning machines, or products designed to clean miscellaneous metallic parts by 

immersion in a container. 

Note that in the proposed definition we are proposing a reorganization. Only the new 

provisions are shown in underline format. The exclusion for "Oven or Grill Cleaner” 

products is being proposed because of modifications proposed to the definition for the 

“Oven or Grill Cleaner” category definition. This is further described in part H of this 

chapter. In general, the Oven or Grill Cleaner category would be limited to products that 

are labeled exclusively to remove baked-on food soils. The definition would further 

clarify that if an Oven or Grill Cleaner product also makes claims that it is suitable for 

general degreasing, that product would be considered a “General Purpose Degreaser.” 

Table VII-7 below summarizes the sales and emissions from nonaerosol General 

Purpose Degreaser products based on the results of the 2006 Survey (ARB, 2007e). 

The data for the 462 reported products have been grown, by population, to 2010. Total 

category sales from these products are about 87,931 pounds per day. 
Technical Support Document Chapter VII - 70 

Table VII-7 

General Purpose Degreaser 

Product Form 

Number of 

Products 

2010 

Category Sales 

(pounds per day) 

2010 Market-Adjusted 

VOC Emissions 

(pounds per day) 

Nonaerosol 462 87,931 3,816 

Also shown in Table VII-7, estimated 2010 market-adjusted VOC emissions for 

nonaerosol General Purpose Degreaser products are 3,816 pounds per day, or about 

1.9 tons per day in California. Although not shown in Table VII-7, the VOC content of 

nonaerosol General Purpose Degreaser products ranges from 0 to 100 percent by 

weight, with a sales-weighted average VOC content of about 3 percent by weight. A 

further explanation of the existence of products above the VOC limit is necessary. 

Review of the 2006 Survey data show that many of the higher VOC content products 

reported are solvent degreasers which, for example, are used for automotive surface 

preparation prior to painting automotive surfaces. Such products correctly reported in 

the 2003 Survey in the unregulated category of "Multi-purpose Solvent." At the time of 

the 2006 Survey, Multi-purpose Solvent products were not subject to VOC restrictions. 

However, changes to the definition for Multi-purpose Solvent products that were 

approved in 2006 clarified that Multi-purpose Solvent products that make claims that 

they are suitable for use as a consumer product which meets another definition in 

section 94508(a) are not Multi-purpose Solvents and are subject to the Most Restrictive 

Limit provision in section 94512(a). Therefore, because automotive surface preparation 

products make degreasing claims, they were correctly reported in the 2006 Survey as 

General Purpose Degreaser products (ARB, 2004a; ARB, 2007e). 

Product Use and Marketing: 

General Purpose Degreaser products are used for a wide range of degreasing duties 

and many are marketed for use in industrial or manufacturing applications, automotive 

maintenance and repair, residential garage or machine shop areas, and similar settings. 

Products marketed for such applications typically remove petroleum-based greases, 

oils, hydrocarbon residues, greasy soils, motor oil, axle grease, hydraulic fluid, lithium 

grease, lubricant oils, silicones, or similar industrial or manufacturing fluids from hard 

surfaces. For example, products are used on machinery, concrete, equipment, 

plumbing or pipe-fittings, tools, floors, walls, miscellaneous metallic or nonmetallic parts, 

and automotive parts. Products are also used to degrease surfaces prior to applying 

paint. 

In addition, General Purpose Degreaser products are marketed for use in food service 

areas including: supermarkets, restaurants, butcher shops or meat-cutting facilities, 

janitorial services, residential and institutional kitchen areas, and similar settings. 

Products marketed for such applications are formulated similarly to Oven or Grill 

Cleaner products and are generally labeled to remove food-related greases or soils. 
Technical Support Document Chapter VII - 71 

These degreaser products can be used on floors, walls, countertops, stoves, ovens, 

grills, appliances or similar surfaces associated with food preparation. Proposed 

changes to the Oven or Grill Cleaner category definition would clarify that a product that 

is labeled as an oven or grill cleaner that makes claims that it is suitable for degreasing 

other hard surfaces is a General Purpose Degreaser.

The General Purpose Degreaser category includes products that are sold as ready-touse (RTU) products or concentrates. Delivery mechanisms for RTU products are 

typically pump sprays or wipes. Products are sprayed, mopped, sponged, wiped, 

brushed, or poured directly onto surfaces. In addition, products can be used in 

automatic dispensing machines or pressure washer systems. It is common for 

concentrated products to display dilution/mixing recommendations and use instructions 

for: “pump spray,” “mop and bucket,” “automatic dispensing systems,” “foaming,” 

“sponge,” “pressure washer,” or combinations based on the surface or substrate, soil 

build-up, or method of application. 

Products can be purchased through many sales outlets including grocery and drug 

stores, discount stores, wholesalers, mass merchandisers, hardware stores, warehouse 

stores, and home centers. Products are also sold to industrial or institutional users 

through distributors or through direct sales by the manufacturer. 

Additional information on product use and marketing can be found in the “1997 Midterm 

Measures I,” “1999 Midterm Measures II,” and the “2006 CONS-2” “Initial Statement of 

Reasons for the Proposed Amendments to the Consumer Products Regulation” (ARB, 

1997b; ARB 1999; ARB, 2006a). 

Product Formulation: 

There are many kinds of degreasing products, but most can be categorized as: alkaline 

water-based, solvent-based, or water-soluble. Product formulations also vary 

depending upon the target market. Factors affecting the strength of the degreaser 

include the product concentration, the solvent or solvents used, the pH of the product, 

and the type of surfactant used. 

Nonaerosol General Purpose Degreaser product formulations often contain water and 

water-soluble solvents such as glycols, glycol ethers, d-limonene, and alcohols (ARB, 

2007e). Nonionic surfactants, such as alcohol ethoxylates or alkylphenol ethoxylates, 

are also used. Many nonaerosol General Purpose Degreaser products are formulated 

to be moderately alkaline, with ingredients such as sodium and potassium silicates, 

alkali metal hydroxides, metasilicates, and ethanolamines. Buffering ingredients such 

as tetra-potassium pyrophosphate or ethylene diamine tetra-acetic acid (EDTA) are 

often found in relatively low concentrations and are used as pH adjusters. Further 

discussion of surfactant technologies is discussed in part C of this chapter. 

Water-based degreasers for heavy degreasing applications often contain higher levels 

of sodium metasilicate, or other metallic carbonates, are of higher pH and generally 
Technical Support Document Chapter VII - 72 

contain more glycol ethers such as 2-butoxyethanol, alcohols such as isopropyl alcohol, 

or d-limonene. Removal of biological oils and greases normally found in the home or 

restaurants, which are primarily triglycerides, can be done effectively by water-based, 

alkaline products with surfactants and little or no organic solvent (ARB, 2007e). Heavyduty alkaline degreasers are often used in commercial or institutional applications such 

as food service facilities or for use in restaurants. 

Many water-based or water containing nonaerosol General Purpose Degreaser 

products are also used to remove motor oils and heavy greases in machine and repair 

shop environments. Some products are formulated with enzymes or live bacteria 

cultures that can digest greases and oils. 

Solvent-based products previously categorized as “Multi-purpose Solvent” can be up to 

100 percent VOC solvent, and typically contain mineral spirits, VM&P Naphtha, toluene, 

xylenes, or other organic solvents. These products are used in surface preparation to 

dissolve grease, wax, or oil on automotive surfaces prior to painting. However, the 

2006 Survey data also show that a number of very low VOC surface preparation 

degreaser products are sold. 

Solvent-based products can also be formulated as an emulsion with solvents such as 

glycol ethers, alcohols, or d-limonene to loosen and solubilize soils such as oily/greasy 

grime, asphalt, creosote, resins, and wax from surfaces. These lipophilic soils are 

solubilized by water-in-oil emulsions. The water in the emulsion acts as a “carrier” for 

the solvent “continuous phase.” Because the solvent is on the outside, the emulsion 

does not have to break for the solvent to be directly exposed to the greasy/oily surface. 

Water-in-oil emulsions are an effective way to use lower amounts of VOC solvent in a 

General Purpose Degreaser product. 

Water-rinsable degreasers are designed to degrease equipment or areas where high 

levels of oils are present, such as plant warehouse concrete floors. The degreaser can 

be pressure sprayed on the surface and wiped or rinsed off with water, at which time an 

emulsion forms, carrying away the product and oils with it. Water-soluble solvent 

degreasers range from those used for degreasing concrete driveways, around loading 

platforms, kitchens, or machine shop areas to specialized foam degreasers or clinging 

foam degreasers used to degrease meat-processing equipment. These products can 

contain hydrocarbon solvents, glycol ethers, and emulsifiers. 

Proposed VOC Limit and Compliance: 

The proposed VOC limit for nonaerosol General Purpose Degreaser products is 

0.5 percent by weight, effective December 31, 2012. As shown in Table VII-8, using 

adjusted 2006 emissions, the proposed limit will result in an estimated emission 

reduction of 2,340 pounds per day, or about 1.17 tons per day in 2012. 
Technical Support Document Chapter VII - 73 

Table VII-8 

General Purpose Degreaser Proposal 

Product Form

Proposed 

VOC Limit

(percent) 

Number of

Complying 

Products

Complying 

Market Share

(percent) 

2012 Emissions 

Reductions 

(pounds per day) 

Nonaerosol 0.5 232 73 2,340 

Table VII-8 also shows that 232 products, representing over 70 percent of the market 

currently comply with the proposed VOC limit of 0.5 percent by weight for 

nonaerosol General Purpose Degreaser products. Complying products are formulated 

with surfactants such as alkyl benzene sulfonate, and alcohol ethoxylates; water 

conditioning agents such as polyacrylates, carbonates, phosphonates, gluconates, 

tetra-potassium pyrophosphate or ethylene diamine tetra-acetic acid (EDTA); alkaline or 

acid builders; and water. Complying products are also formulated with the following 

LVP-VOC ingredients: glycol ethers, methyl esters, triethanolamine, and hydrocarbon 

solvents. 

To comply with the proposed VOC limit of 0.5 percent by weight, we predict 

manufacturers will reformulate products with based on use of: surfactant technologies; 

non-VOC alkaline ingredients; LVP-VOC solvent substitutions; or water-solvent 

emulsions using LVP-VOC glycol ethers or LVP-VOC hydrocarbon solvents. 

Proposal to Prohibit Use of Alkylphenol Ethoxylate Surfactants: 

Alkylphenol ethoxylate surfactants, in particular the octylphenol and nonylphenol 

ethoxylates, are known to be toxic to aquatic species. We are aware that some General 

Purpose Degreaser (nonaerosol) products contain these compounds. Because of this, 

ARB staff consulted with State Water Resources Control Board (SWRCB) staff to 

determine if continued use of these compounds could adversely affect water quality. 

Information provided to SWRCB staff indicates that alkylphenol ethoxylates were found 

in measurable concentrations in the State’s receiving waters. Therefore, SWRCB staff 

expressed concern that any potential increased use of alkylphenol ethoxylate 

surfactants could adversely impact aquatic species (SWRCB, 2010a; SWRCB, 2010b; 

SCCWRP, 2010; and SFEI, 2010). In light of this finding, we are proposing a CEQA 

mitigation measure to ensure that use of alkylphenol ethoxylate surfactants does not 

occur as products reformulate. As proposed, section 94509(m)(3) would preclude use 

of alkylphenol ethoxylate surfactants in General Purpose Degreaser (nonaerosol) 

products effective December 31, 2012. Further information on this proposal, as well as 

the need, is contained in Chapters VI and IX. 

E. Glass Cleaner (nonaerosol)

“Glass Cleaner” products are designed primarily for cleaning surfaces made of glass 

such as windows, mirrors, glass tabletops, and computer screens. Products designed 

solely for the purpose of cleaning optical materials used in eyeglasses, photographic 
Technical Support Document Chapter VII - 74 

equipment, scientific equipment, or photocopying machines are excluded from the 

Glass Cleaner category. Products marketed as "Glass and Surface Cleaner" are also 

not included in this category; they are “General Purpose Cleaner” products. 

Glass Cleaner products were first regulated under the Phase-I amendments approved 

by the Board approved in October of 1990 (ARB, 1990). At that time, the Board 

approved a VOC limit of 8 percent by weight for nonaerosol Glass Cleaner products, 

effective January 1, 1993. The current VOC limit for nonaerosol Glass Cleaner 

products is 4 percent by weight, which has been in effect since December 31, 2004. 

The 2006 Survey provides the basis for our determination that it is commercially and 

technologically feasible to further reduce the VOC content of these products. Based on 

these data, staff is proposing to lower the VOC limit for nonaerosol Glass Cleaner 

products to 3 percent by weight. 

Table VII-9 below summarizes the sales and emissions from nonaerosol Glass Cleaner 

products based on the results of the 2006 Survey (ARB, 2007e). The data for the 

298 reported products have been grown, by population, to 2010. Total category sales 

from these products are about 149,812 pounds per day. 

Table VII-9 

Glass Cleaner 

Product Form 

Number of 

Products 

2010 

Category Sales 

(pounds per day) 

2010 Market-Adjusted 

VOC Emissions 

(pounds per day) 

Nonaerosol 298 149,812 6,685 

As shown in Table VII-9, nonaerosol Glass Cleaner products have estimated VOC 

emissions of 6,685 pounds per day, or about 3.3 tons per day in California. Nonaerosol 

products represent 96 percent of Glass Cleaner products sold in California. Although 

not shown, the sales-weighted average VOC content is about 3.4 percent by weight. 

Product Use and Marketing: 

The Glass Cleaner (nonaerosol) category consists of cleaning products that are labeled 

for use on glass surfaces. In addition to window cleaning, these cleaners are used to 

remove soils from glass furniture, fixtures, mirrors, or special surfaces such as stained 

glass. Nonaerosol Glass Cleaner products are formulated as ready-to-use (RTU) pump 

spray or wipes, or as concentrates which require dilution by the consumer before use. 

Nonaerosol Glass Cleaner products are applied and wiped off with a cloth or paper 

towel. A very small number of products are diluted during use. These “hose-connect” 

products are designed for the cleaning of exterior glass surfaces and windows. 

Certain Glass Cleaner products also claim to provide special properties to the cleaned 

surface. For example, some products claim to provide anti-fogging properties. 
Technical Support Document Chapter VII - 75 

Glass Cleaner products are sold to household consumers, janitors, hospitality industries 

and other commercial or institutional establishments for glass cleaning. They are 

available at grocery stores, discount stores, janitorial supply stores, and warehouse 

stores. They may also be sold directly to institutional and commercial facilities. 

Glass Cleaner products are used by household, commercial, and industrial 

establishments. Depending on the cleaning application, both the delivery method and 

product form varies. RTU pump spray products appear to be preferred by the 

household consumer. In a household setting Glass Cleaner products are used to clean 

a variety of soils on glass surfaces such as food, grease, and oils (including sebum, 

such as fingerprints) in addition to dust and other particulate. Oily soils and particulate 

also need to be removed from inside vehicles windows. In addition, consumers use 

Glass Cleaner products to remove outdoor soils including mineral deposits, hard water 

stains, dirt, and heavier soils including animal deposits. To clean these household soils, 

desirable performance characteristics include ease of use, quick drying, and 

effectiveness in soil removal, such that the product does not produce or leave streaks 

and/or solids on the glass surface. 

Most Glass Cleaner products sold to commercial and industrial establishments are 

concentrated products. Following dilution these products are applied to mirrors, highrise exterior and interior windows, “clear-guards” at food establishments, along 

manufacturing lines, or other glass surfaces. End users can mix the appropriate parts of 

water and cleaner manually with measuring devices, but some vendors also supply 

closed-loop dispensing and proportioning systems for automated dilution. Dispensers 

and proportioners work by using a metering tip to mix the product with the 

recommended amount of water to proper concentration (Schafer, 2008). 

Product Formulation: 

Nonaerosol Glass Cleaner products are commonly formulated with a high water 

content. Short carbon chains alcohols such as isopropyl or ethyl and/or glycol ethers 

are used to dissolve oily soils. Some products are also formulated with vinegar (dilute 

acetic acid), exempt VOCs, and ammonia. Small amounts of surfactants are included 

to emulsify oily soils. The surfactant also creates a layer of foam which allows the 

product to cling to the surface. Fragrance is also routinely added in small amounts. 

Proposed VOC Limit and Compliance: 

The proposed VOC limit for nonaerosol Glass Cleaner products is 3 percent by weight, 

effective December 31, 2012. As shown in Table VII-10, the proposed VOC limit would 

result in an estimated emission reduction of 827 pounds per day, or 0.41 tons per day 

statewide in 2012. 
Technical Support Document Chapter VII - 76 

Table VII-10 

Glass Cleaner Proposal 

Product Form

Proposed 

VOC Limit 

(percent)

Number of 

Complying 

Products

Complying 

Market Share 

(percent)

2012 Emissions 

Reductions 

(pounds per day) 

Nonaerosol 3 165 10 827 

As shown in Table VII-10, a large number of products already comply with the proposed 

3 percent by weight VOC limit, however, the overall complying market share is relatively 

low. For most nonaerosol Glass Cleaner products, reformulation to meet the proposed 

VOC limit will involve adjusting the water content, reducing the amount of VOC solvents, 

or replacing VOC solvents with LVP-VOC solvents, exempt VOCs, or surfactants. We 

expect most noncomplying products will reformulate with a smaller amount of VOC 

glycol ether or alcohol, with the balance being water and surfactants. 

Proposal to Prohibit Use of Alkylphenol Ethoxylate Surfactants: 

Alkylphenol ethoxylate surfactants, in particular the octylphenol and nonylphenol 

ethoxylates, are known to be toxic to aquatic species. We are aware that some Glass 

Cleaner (nonaerosol) products contain these compounds. Because of this, ARB staff 

consulted with State Water Resources Control Board (SWRCB) staff to determine if 

continued use of these compounds could adversely affect water quality. Information 

provided to SWRCB staff indicates that alkylphenol ethoxylates were found in 

measurable concentrations in the State’s receiving waters. Therefore, SWRCB staff 

expressed concern that any potential increased use of alkylphenol ethoxylate 

surfactants could adversely impact aquatic species (SWRCB, 2010a; SWRCB, 2010b; 

SCCWRP, 2010; and SFEI, 2010). In light of this finding, we are proposing a CEQA 

mitigation measure to ensure that use of alkylphenol ethoxylate surfactants does not 

occur as products reformulate. As proposed, section 94509(m)(3) would preclude use 

of alkylphenol ethoxylate surfactants in Glass Cleaner (nonaerosol) products effective 

December 31, 2012. Further information on this proposal, as well as the need, is 

contained in Chapters VI and IX. 

Issues: 

1. Issue: The proposed 3 percent VOC limit should be lower. 

Response: Staff’s evaluation of the 2006 Survey indicate that the complying 

market share at the proposed 3 percent limit is low (about 10 percent). Although 

there are a number of products that comply, their overall sales are low. Some of 

the complying products are designed solely to be diluted in a bucket for outdoor 

window cleaning. This type of product is not suitable for indoor use. Staff also 

reviewed data that show that when the amount of VOC cleaning solvent is 

reduced there are potential safety hazards. For example, in automotive glass, 
Technical Support Document Chapter VII - 77 

streaks or haze left behind from inadequate cleaning, or excess residuals can 

lead to haze and unsafe driving conditions. Therefore, staff believes the 

3 percent VOC limit is appropriate. 

F. Heavy-duty Hand Cleaner or Soap (nonaerosol) 

Heavy-duty Hand Cleaner or Soap products are designed to clean or remove difficult 

dirt and soils from the hand with or without the use of water. Products remove a variety 

of tough soils including oil, grease, grime, tar, shellac, putty, printer’s ink, paint, 

graphite, cement, carbon, asphalt, or adhesives. The Heavy-duty Hand Cleaner or 

Soap category does not include prescription drug products, Antimicrobial Hand or Body 

Cleaner or Soap, Astringent/Toner, Facial Cleaner or Soap, General-use Hand or Body 

Cleaner or Soap, or Rubbing Alcohol. 

Heavy-duty Hand Cleaner or Soap products are currently subject to a VOC limit of 

8 percent by weight for all product forms, which has been in effect since January 1, 

2005 (ARB, 1997a). A description of these products is also included in the staff report 

for that rulemaking, the Midterm Measures I (ARB, 1997b). 

In this rulemaking, we are proposing to reduce the VOC limit to 1 percent by weight for 

nonaerosol Heavy-duty Hand Cleaner or Soap products. These products are sold as 

liquids (which include wipes and pump spray), semisolids, and solids. The current VOC 

limit of 8 percent by weight for aerosol Heavy-duty Hand Cleaner or Soap products will 

be retained. 

Table VII-11 below summarizes the sales and emissions from nonaerosol Heavy-duty 

Hand Cleaner or Soap products based on the results of the 2006 Survey (ARB, 2007e). 

The data have been grown, by population, to 2010. Total category sales for the 255 

reported products are about 26,093 pounds per day. 

Table VII-11 

Heavy-duty Hand Cleaner or Soap 

Table VII-11 also shows the 2010 market-adjusted VOC emissions are 1,585 pounds 

per day, or about 0.79 tons per day, statewide. Although not shown, the sales-weighted 

average VOC content is about 4.6 percent. 

Product Use and Marketing: 

Nonaerosol Heavy-duty Hand Cleaner or Soap products are found and used in the 

home, garage, business, manufacturing, construction and mobile business settings 

Product Form 

Number of 

Products 

2010 

Category Sales 

(pounds per day) 

2010 Market-Adjusted 

VOC Emissions 

(pounds per day) 

Nonaerosol 255 26,093 1,585 
Technical Support Document Chapter VII - 78 

(CSPA, 2010b). These products are commonly used to remove the toughest dirt and 

soils that cannot be easily washed off with general-use soaps. Typically, the hand 

cleaner is rubbed into dry or wet hands until the dirt and soils are dissolved or 

suspended in the product. In the 2006 Survey, about 10 percent of the liquid products 

reported were towelette (wipe) products. Except for towelette products, virtually all the 

products instruct the user to wipe the hands with a towel or cloth to remove the dirt or 

soil suspended in the product, or first rinse with water and then follow with hand wiping. 

After rinsing with water, hands are often dried with a towel or cloth to aid in 

mechanically removing product or any stubborn soils that remain on the skin 

(Willard et. al, 2005). 

Nonaerosol Heavy-duty Hand Cleaner or Soap products are typically sold in automotive 

supply stores, discount stores, hardware stores, home supply stores, paint stores, 

hobby and craft stores, and through Internet sales and catalog sales. These products 

are also sold to industrial or institutional users through distributors or through direct 

sales by the manufacturers. 

Product Formulation: 

Nonaerosol Heavy-duty Hand Cleaner or Soap products typically contain water, 

surfactants (anionic and nonionic), VOC and/or LVP-VOC solvents, and abrasives. 

These ingredients assist in removing tough dirt and soils from the hands. In addition, 

nonaerosol Heavy-duty Hand Cleaner or Soap products may contain fragrance and 

moisturizing agents. The VOC content of the reported nonaerosol Heavy-duty Hand 

Cleaner or Soap products ranges from 0 to 8 percent by weight. 

Nonaerosol Heavy-duty Hand Cleaner or Soap products are commonly formulated with 

water in combination with surfactants to suspend dirt and grease. Approximately 

95 percent of the products reported in the 2006 Survey reported having water in the 

product formulation. In products containing water, the water content ranged from near 

0 to 95 percent by weight, with a sales-weighted average of approximately 60 percent

(ARB, 2007e). 

Use of both anionic and nonionic surfactants is common. Among the surfactants used 

are diethanolamine, sodium lauryl sulfate, alkylphenol ethoxylates, ethoxylated alcohols, 

and PEG-6 tridecyl ether (ARB, 2007e). 

Typical VOC solvents used in nonaerosol Heavy-duty Hand Cleaner or Soap products 

include hydrocarbon solvents, such as mineral spirits, and terpenes, such as 

d-limonene. These hand cleaners have a VOC content ranging from 1 to 8 percent by 

weight. The VOC solvents may act as both an active ingredient by dissolving dirt and 

soils, or as a carrier for other ingredients. Use of LVP-VOC hydrocarbon and methyl 

ester solvents was also reported. 

 

Abrasives are active ingredients which remove dirt through physical action. Examples 

of abrasives are pumice, silica, diatomaceous earth, and polybeads. Bio-based 
Technical Support Document Chapter VII - 79 

abrasives include ground nut shells or seeds and corn cob grit. Products with abrasives 

typically come with use instructions to towel off or rinse off the product with water after 

the cleansing process to achieve residue-free hands (ARB, 2007e). As reported in the 

2006 Survey, the amount of abrasives used in nonaerosol Heavy-duty Hand Cleaner or 

Soap products ranges from 0 to 53 percent of the product weight, with a sales-weighted 

average of about 8 percent by weight. 

Moisturizers and fragrances may be included in the formulation of nonaerosol Heavyduty Hand Cleaner or Soap products. Common moisturizers include aloe vera, jojoba 

oil, lanolin, and mineral oil to help condition the skin and prevent drying. 

A number of nonaerosol Heavy-duty Hand Cleaner or Soap products are labeled to 

remove paint and adhesives from the hands. Most, if not all of these hand cleaners, 

contain the dibasic esters dimethyl adipate or dimethyl succinate. Dimethyl succinate is 

a VOC while dimethyl adipate is a LVP-VOC. Both are used in the formulation because 

of their ability to dissolve the paint resins (ARB, 2007e). 

Proposed VOC Limit and Compliance: 

The proposed VOC limit for nonaerosol Heavy-duty Hand Cleaner or Soap products is 

1 percent by weight with an effective date of December 31, 2013. As shown in 

Table VII-12, the proposed VOC limit would result in emission reductions of 

1,051 pounds per day, or about 0.53 tons per day, statewide in 2013. 

Also shown in Table VII-12, 113 products, representing 30 percent of the market 

already comply with the proposed VOC limit of 1 percent by weight, demonstrating that 

the proposed VOC limit is technologically and commercially feasible. 

Table VII-12 

Heavy-duty Hand Cleaner or Soap Proposal 

Product Form

Proposed 

VOC Limit 

(weight percent)

Number of

Complying 

Products

Complying 

Market Share

(percent) 

2013 Emissions 

Reductions 

(pounds per day) 

Nonaerosol 1 113 30 1,051 

For most nonaerosol Heavy-duty Hand Cleaner or Soap products, reformulation to meet 

the proposed VOC limit of 1 percent by weight will involve adjusting the water content, 

reducing the amount of VOC solvents or replacing VOC solvents with LVP-VOC 

solvents, increasing the amount of surfactants or abrasives, or a combination of the 

above. The proposed limit will not require a change in the amount of moisturizing 

agents (aloe vera, jojoba oil, lanolin, mineral oil) used in the formulation of the product. 

These moisturizing agents are LVP-VOCs which are not counted toward a product’s 

VOC content. 
Technical Support Document Chapter VII - 80 

Approximately 60 percent of the 113 products that comply with the proposed VOC limit 

of 1 percent by weight contain abrasives. Thus, use of these materials appears to be a 

viable reformulation strategy. 

To allow manufacturers the needed time to reformulate all noncomplying products, staff 

is proposing December 31, 2013, as the effective date of the proposed VOC limit. 

Proposal to Prohibit Use of Alkylphenol Ethoxylate Surfactants: 

Alkylphenol ethoxylate surfactants, in particular the octylphenol and nonylphenol 

ethoxylates, are known to be toxic to aquatic species. We are aware that some Heavyduty Hand Cleaner or Soap (nonaerosol) products contain these compounds. Because 

of this, ARB staff consulted with State Water Resources Control Board (SWRCB) staff 

to determine if continued use of these compounds could adversely affect water quality. 

Information provided to SWRCB staff indicates that alkylphenol ethoxylates were found 

in measurable concentrations in the State’s receiving waters. Therefore, SWRCB staff 

expressed concern that any potential increased use of alkylphenol ethoxylate 

surfactants could adversely impact aquatic species (SWRCB, 2010a; SWRCB, 2010b; 

SCCWRP, 2010; and SFEI, 2010). In light of this finding, we are proposing a CEQA 

mitigation measure to ensure that use of alkylphenol ethoxylate surfactants does not 

occur as products reformulate. As proposed, section 94509(m)(3) would preclude use 

of alkylphenol ethoxylate surfactants in Heavy-duty Hand Cleaner or Soap (nonaerosol) 

products effective December 31, 2013. Further information on this proposal, as well as 

the need, is contained in Chapters VI and IX. 

 

Issues: 

1. Issue: A proposed 1 percent by weight VOC limit for nonaerosol Heavy-duty 

Hand Cleaner or Soap products could result in an increase in the use of LVPVOC ingredients. Substituting VOC ingredients with LVP-VOC ingredients would 

contribute to increased product residue left on hands, making hands sticky or 

slippery. This potentially causes unsafe situations for emergency response and 

utility workers out in the field without a source of running water. 

Response: Staff identified that one reformulation option is to use more 

LVP-VOC ingredients. However, the commenter did not provide sufficient 

information to staff to support their claims that such reformulated products would 

result in more residue left on hands and lead to unsafe situations. Use 

instructions on the labels indicate that products intended to be used without 

water are to be wiped off with paper towels or cloths; this action should remove 

much of the residue from the hands. Complying towelette products were also 

reported in the 2006 Survey. In addition, staff contacted representatives of 

potential users, including fire fighters, emergency medical technicians (EMT), 

and utility workers. Staff was told that these workers typically wear gloves when 

out on calls. According to the organizations contacted by staff, firefighters do not 

take nonaerosol Heavy-duty Hand Cleaner or Soap products out on calls but 
Technical Support Document Chapter VII - 81 

would use such products to clean their hands upon their return to the station. 

EMTs do not take nonaerosol Heavy-duty Hand Cleaner or Soap out on calls. A 

utility representative indicated that the field workers do take nonaerosol Heavyduty Hand Cleaner or Soap products with them but use of such products is 

limited because the workers would be wearing gloves. 

2. Issue: Products with 1 percent by weight VOC content would not meet the 

rigorous performance requirements of heavy-duty hand cleaners.

Response: Heavy-duty Hand Cleaner or Soap product is currently defined as a 

product designed to clean or remove difficult dirt and soils such as oil, grease, 

grime, tar, shellac, putty, printer’s ink, paint, graphite, cement, carbon, asphalt, or 

adhesives from the hand with or without the use of water. According to label 

claims, many of the 113 complying products reported in the 2006 Survey are 

designed to clean or remove a variety of such soils. 

 

3. Issue: A proposed 1 percent by weight VOC limit for nonaerosol Heavy-duty 

Hand Cleaner or Soap products could result in an increase in the use of abrasive 

ingredients. Increased amounts of abrasive ingredients will potentially be 

washed “down the drain,” impacting water treatment and increasing solid waste. 

Response: Staff identified that a reformulation option is to use more abrasive 

ingredients. However, staff has no reason to believe that the reformulation of 

nonaerosol Heavy-duty Hand Cleaner or Soap products would have significant 

adverse impacts on water treatment or solid waste disposal systems. 

Approximately 60 percent of the 113 products that comply with the proposed 

VOC limit of 1 percent by weight contain abrasives with 12 products containing 

less than 1 percent by weight. About half of the complying products contain very 

little or no abrasive ingredients, indicating that product reformulations that do not 

rely on increase use of abrasives are just as likely. 

 

4. Issue: CSPA and its members have provided ARB staff with a counterproposal 

for a VOC limit of 5 percent by weight. 

Response: As shown by the 2006 Survey, numerous products currently comply 

with staff’s proposed 1 percent by weight VOC limit and are available, and based 

on the sales data, are well accepted by consumers. In addition, the 30 percent 

complying market share, with 113 complying products out of 255 products, 

indicates that the proposed limit is both technologically and commercially 

feasible. 

5. Issue: An exemption of 5 percent by weight should be provided for ‘bio-based’ 

VOC solvents. These solvents are better for the environment than are 

petroleum-based solvents. 
Technical Support Document Chapter VII - 82 

Response: Use of petroleum-based solvents is not the only reformulation 

option. The data show that the proposed 1 percent limit is feasible using a 

variety of reformulation options. While some products are currently formulated 

with bio-based solvents such as d-limonene, many other products do not contain 

this VOC. Products can also be reformulated to meet the 1 percent VOC limit 

without petroleum-based solvents. For example use of the LVP-VOC bio-based 

soy methyl ester solvents is a feasible reformulation option. Products can also 

be formulated without VOC or LVP-VOC solvents. Use of surfactants with water, 

and use of bio-based abrasives are also feasible options. 

G. Metal Polish or Cleanser

Metal Polish or Cleanser is defined as “any product designed or labeled to improve the 

appearance and/or protect finished metal, metallic, or metallized surfaces by physical or 

chemical action. To “improve the appearance” means to clean, remove, or reduce 

stains, impurities, or oxidation from surfaces or to make surfaces smooth and shiny. 

“Metal Polish/Cleanser” includes, but is not limited to metal polishes used on brass, 

silver, chrome, copper, stainless steel and other ornamental metals. “Metal 

Polish/Cleanser” does not include “Automotive Wax, Polish, Sealant or Glaze,” “Tire or 

Wheel Cleaner,” “Paint Remover or Stripper,” products designed and labeled 

exclusively for automotive and marine detailing, or products designed for use in 

degreasing tanks.” 

A number of Metal Polish/Cleansers were reported for use on a single metallic surface. 

However, some Metal Polish/Cleansers are designed for use on a variety of substrates 

and are labeled as multi-surface Metal Polish/Cleansers. 

Metal Polish/Cleansers were first regulated in 1997 (ARB, 1997b). Products were 

required to meet a VOC limit of 30 percent by weight, effective January 1, 2005. In the 

current rulemaking, we are proposing a further VOC reduction for Metal 

Polish/Cleansers. To maximize reductions, we are also proposing to divide the 

category into aerosol and nonaerosol product forms. We are also proposing to change 

the category name from Metal Polish/Cleanser to “Metal Polish or Cleanser” to clarify 

that products making either claim are subject to the VOC limits. 

Table VII-13 below summarizes the sales and emissions of aerosol and nonaerosol 

Metal Polish or Cleanser products based on the results of the 2006 Survey (ARB, 

2007e). The data for the 227 reported products have been grown, by population, to 

2010. As shown in Table VII-13, category sales for the 73 reported aerosol products 

are about 2,097 pounds per day. The 154 reported nonaerosol products have sales of 

about 10,522 pounds per day. 
Technical Support Document Chapter VII - 83 

Table VII-13 

Metal Polish or Cleanser 

Product Form 

Number of 

Products 

2010 

Category Sales 

(pounds per day) 

2010 Market-Adjusted 

VOC Emissions 

(pounds per day) 

Aerosol 73 2,097 437 

Nonaerosol 154 10,522 409 

Table VII-13 also shows the 2010 market-adjusted VOC emissions for aerosol products 

are 437 pounds per day, or about 0.22 tons per day. Table VII-13 also shows that the 

2010 market-adjusted VOC emissions for nonaerosol products are 409 pounds per day, 

or about 0.20 tons per day. Although not shown, the sales-weighted average VOC 

content is about 21 percent by weight for aerosol products and 4 percent by weight for 

nonaerosol products. 

Product Use and Marketing: 

As mentioned earlier, Metal Polish or Cleanser products are used to improve the 

appearance of finished metal, metallic or metalized surfaces by physical or chemical 

action. Metal Polish or Cleanser products remove dust, fingerprints, tarnish, and many 

products claim to provide protection from future tarnishing (CSPA, 2010a). Tarnish is 

the result of the reaction of metal surfaces with pollutants in the air. Pollutants, such as 

nitrogen oxides, sulfur oxides and carbon monoxide, dissolve in the moisture in the air 

to form acidic solutions. These acidic solutions further react with the metal surfaces to 

produce tarnish (CSPA, 2010a). 

Because of the differences in metal hardness and uses, polishes are designed to work 

without scratching the metal (CSPA, 2010a). Silver and aluminum have a fairly soft 

surface. Brass, copper, bronze and pewter surfaces are considered to have 

intermediate hardness. Soft and intermediate surface cleaners remove soil build up and 

tarnish, and claim to leave a smooth polished surface, and prevent further oxidation and 

corrosion. Stainless steel and chrome surfaces are considered hard and more durable. 

Cleaners for these metals are designed to leave a streak free appearance, remove 

soils, and leave a protective coating. 

Metal Polish or Cleanser products are used in both household and institutional settings. 

These products are available in aerosols; liquids; semisolids, such as pastes or creams; 

and solids (ARB, 2007e). 

A household consumer will use these products for a variety of cleaning and polishing 

needs around the home. Examples include, cleaning and polishing appliances, jewelry, 

flatware, fireplace accessories, home furnaces, metal surfaced or coated items, 

decorative trim, appliances, kitchen or bathroom fixtures, brass doors, end plates, wall 

coverings and railings. 
Technical Support Document Chapter VII - 84 

In institutional settings such as restaurants, hotels, office buildings and hospitals, Metal 

Polish or Cleanser products are used to clean metal objects such as stainless steel 

surfaces, brass railings, brass fixtures, stovetops and decorative objects. 

Metal Polish or Cleaner products that clean by physical action include liquids, 

semisolids and solids. These products require some physical scrubbing action to clean 

and shine the metallic substrate. Liquid products are usually applied using a moist 

cloth. After a short period of time the product is rinsed off with water and wiped or 

buffed off with a clean sponge or cloth. Semisolids typically clean through abrasion. 

They are applied with a damp cloth, rubbed onto the substrate and then wiped or rinsed 

off with soap and water. 

Metal Polish or Cleanser products that clean by chemical action are typically liquids and 

aerosols that have a higher VOC content. Generally, these products are applied using 

a clean soft cloth, allowed to dry after slight rubbing to loosen badly discolored areas, 

and polished with a soft, dry cloth. Some liquids are available as dips in which objects 

are placed into the container of liquid product, pulled out and wiped or rinsed off to get a 

clean shiny appearance. Aerosol products, based on product labels, appear to be used 

for quick spot cleaning to get into hard to clean crevices. According to the 2006 Survey, 

aerosol products are more widely used in the institutional market than the household 

market (ARB, 2007e). 

Metal Polish or Cleanser products are sold at numerous locations such as department 

stores, grocery stores, hardware stores, hobby shops, warehouse stores, paint stores, 

and janitorial supply stores. 

Product Formulation: 

Metal Polish or Cleanser products are formulated with water and a variety of VOC 

ingredients. VOC ingredients reported include various hydrocarbon solvents, alcohols, 

terpenes, and/or glycol ethers. Limited use of xylenes and perchloroethylene was 

reported. A number of products also contain an LVP-VOC mineral oil which provides a 

protective coating on the surface. Some products also contain a small amount of 

fragrance. Depending on the function of the Metal Polish or Cleanser product, 

formulations may also include weak acids or ammonia. Ingredients, such as abrasive 

polishing agents, did not have to be speciated in the 2006 Survey. However, review of 

product labels lists ingredients such as silica, diatomaceous earth, talc, chalk, pumice, 

or clay as the abrasive polishing agents. The type of abrasive polish agent used in 

products depends on the hardness of the metal to be polished. 

The propellants reported for aerosol products are hydrocarbon blends of propane, 

butane, and iso-butane. The range of propellant reported is about 5 to 30 percent by 

weight. 

A typical stainless steel cleaner product contains water, VOC hydrocarbon solvent, 

alcohol, d-limonene, fragrance, and an LVP-VOC mineral oil. Use of acetone was also 
Technical Support Document Chapter VII - 85 

reported. The mineral oil deposits a protective coating on the surface. A hydrocarbon 

propellant is typically used in the aerosol product form, however, a few products 

reported use of carbon dioxide. 

A typical tarnish remover contains water, VOC hydrocarbon solvent, alcohol, ammonia, 

LVP-VOC solvent, exempt compounds, clay or silica, acid, and/or fragrance. 

Hydrocarbon propellants are used in the aerosol product form. 

A typical polish contains water, VOC hydrocarbon solvent, alcohol, glycol ether, LVPVOC mineral oil, abrasives such as pumice, clay, or silica, inorganic compounds, 

ammonia, acid, and/or fragrance. Hydrocarbon propellants are typically used in the 

aerosol product form.

Proposed VOC Limit and Compliance: 

The proposed VOC limit for aerosol Metal Polish or Cleanser products is 15 percent by 

weight. The proposed VOC limit for nonaerosol Metal Polish or Cleanser products is 

3 percent by weight. These VOC limits would become effective December 31, 2012. 

As shown in Table VII-14, using adjusted emissions, the proposed VOC limits would 

result in VOC emission reductions of approximately 440 pounds per day, or about 

0.22 tons per day in 2012. 

Table VII-14 

Metal Polish or Cleanser Proposal 

Product Form

Proposed 

VOC Limit 

(weight percent) 

Number of

Complying 

Products 

Complying 

Market Share 

(percent)

2012 Emissions 

Reductions 

(pounds per day) 

Aerosol 15 20 35 140 

Nonaerosol 3 96 78 300 

Table VII-14 also shows 35 percent of the market already complies with the proposed 

aerosol VOC limit of 15 percent by weight. For nonaerosol products, 78 percent of the 

market complies with the proposed VOC limit of 3 percent by weight. 

A typical complying nonaerosol stainless steel cleaner contains up to 80 percent water, 

with the balance being a combination of grouped LVP-VOC and alcohol. A typical 

complying aerosol stainless steel cleaner contains similar ingredients with about 

10 percent hydrocarbon propellant. 

A typical complying tarnish remover contains up to 64 percent water. Other reported 

ingredients include inorganic compounds, clay, small amounts of ammonia, VOC 

hydrocarbon solvent, and fragrance. A typical complying aerosol tarnish remover 

contains similar ingredients with about 10 percent hydrocarbon propellant. 
Technical Support Document Chapter VII - 86 

A typical complying polish contains about 50 percent water. Other reported ingredients 

include inorganic compounds, silica, a small amount of mineral oil, a small amount of 

alcohol, and a weak acid. A typical complying aerosol polish contains similar 

ingredients with about 10 percent hydrocarbon propellant. 

We expect noncomplying products to reformulate using similar ingredients and 

technologies as the current complying products. Reformulation options include use of 

water, LVP-VOC hydrocarbon solvents, abrasives, VOC exempt compounds, or any 

combination. 

Proposal to Prohibit Use of Certain TAC Solvents: 

We are proposing a CEQA mitigation measure to prohibit the use of the chlorinated 

TAC solvents methylene chloride, perchloroethylene, and trichloroethylene in Metal 

Polish or Cleanser products. The prohibition of these three solvents is necessary, 

particularly for methylene chloride and perchloroethylene, because they are exempt 

VOCs and could be used in reformulated products without ‘counting’ toward VOC 

content. For this rulemaking, staff’s evaluation of the 2006 Survey data show 

formulation technologies that do not contain methylene chloride, perchloroethylene, or 

trichloroethylene are readily available, and are not needed to comply with the proposed 

limits. This provision would become effective on December 31, 2012. More information 

on this proposal is contained in Chapter IX, Environmental Impacts, Section E. 

Proposed GWP Limit: 

 

No compounds with GWP values at or above 150 were reported in the 2006 Survey for 

this category. However, to ensure that use of compounds with higher GWP values does 

not begin as products reformulate to comply with the proposed VOC limits, we are 

proposing a GWP limit of 150 for any chemical compound used in Metal Polish or 

Cleanser products, effective December 31, 2012. While this proposal would allow use 

of the non-VOC propellant, HFC-152a, we believe other reformulation options are more 

likely. The proposed limit would not apply to any chemicals present as contaminants, 

which in aggregate are 0.1 percent by weight or less. This limit is proposed as a 

mitigation measure under CEQA (see Chapter IX, Environmental Impacts. Section E). 

The proposed limit is contained in section 94509(n). 

H. Oven or Grill Cleaner 

“Oven Cleaner” products are designed to remove cooked or baked-on food soils from 

the inside of oven surfaces or similar cooking surfaces. Nonaerosol Oven or Grill 

Cleaner products are currently subject to a 1 percent by weight VOC limit, which has 

been in effect since December 31, 2008. At that time Oven Cleaner products were 

primarily caustic products. 

As part of the 2006 Survey, data for grill cleaning products was obtained. Our 

evaluation of the grill cleaner products indicates that these products are similarly 
Technical Support Document Chapter VII - 87 

formulated and have similar functions to Oven Cleaner products. Because they have 

similar functions we are proposing to add grill cleaning products into the existing Oven 

Cleaner category and rename the category to “Oven or Grill Cleaner.” Products in this 

combined category are often labeled as: “Oven Cleaner,” “Oven or Grill Cleaner,” 

“Oven Cleaner and Heavy Duty Degreaser,” “Grill and Fryer Cleaner,” or “Grill Cleaner.” 

During our evaluation we also learned that less harsh VOC technologies are available 

as alternatives to caustic products. These products require a higher VOC content than 

would be allowed by the 1 percent VOC limit. Therefore, we are proposing to increase 

the VOC limit for Oven or Grill Cleaner products slightly to allow for use of these 

alternatives. 

We are also proposing to clarify that an Oven or Grill Cleaner product making other 

general degreasing claims is a “General Purpose Degreaser” product. Likewise, we are 

proposing to clarify that a Oven or Grill Cleaner product making general cleaning claims 

is a “General Purpose Cleaner” product. The proposed changes to the definition are 

shown below in strikethrough/underline format. 

“Oven or Grill Cleaner” means any cleaning a product designed or labeled exclusively to 

clean and to remove dried or baked on greases and/or food deposits from oven walls

food preparation and/or food cooking surfaces. A product that is labeled as an “Oven or 

Grill Cleaner” that makes claims that it is suitable for degreasing other hard surfaces is 

a “General Purpose Degreaser.” A product that is labeled as an “Oven or Grill Cleaner” 

that makes claims that it is suitable for cleaning other hard surfaces is a “General 

Purpose Cleaner.”

Surfaces likely to be soiled with baked-on greases and/or deposits that would require 

use of an Oven or Grill Cleaner product include: ovens, grills, broilers, deep fat fryers, 

rotisseries, stove hoods, exhaust vents, oven racks, bakery carts, or drip pans. 

Oven Cleaner products were defined and regulated under the Phase-I amendments 

approved by the Board in October 1990 (ARB, 1990). At that time, the Board approved 

an 8 percent by weight VOC limit for aerosol and pump spray product forms, and a 

5 percent by weight VOC limit for liquid product forms. The VOC limits became 

effective on January 1, 1993. 

At the November 16, 2006, hearing, the Board approved amendments to lower the VOC 

limit for nonaerosol Oven Cleaner products (thereby incorporating pump spray and 

liquid products into a single subcategory) to 1 percent by weight, effective 

December 31, 2008. The 1 percent by weight VOC limit for nonaerosol products was 

determined to be technologically and commercially feasible based on the data reported 

(ARB, 2004a). In addition, a prohibition on the use of the TACs methylene chloride, 

perchloroethylene, and trichloroethylene was put in place. 

Table VII-15 below, summarizes the sales and emissions from the Grill Cleaner 

products that we are incorporating into the Oven or Grill Cleaner category 
Technical Support Document Chapter VII - 88 

(ARB, 2007e). Data for the 111 reported products have been grown to 2010. As shown 

in Table VII-15, total Grill Cleaner product sales are about 32,898 pounds per day in 

California. 

Table VII-15 

Oven or Grill Cleaner *

Product Form 

Number of 

Products 

2010 

Category Sales 

(pounds per day)

2010 Market-Adjusted 

VOC Emissions 

(pounds per day)

Aerosol 21 1,868 162 

Nonaerosol 90 31,030 479 

*Data are for Grill Cleaner products only. Oven Cleaner products were surveyed in 2003. 

Table VII-15 also shows aerosol Grill Cleaner products have estimated VOC emissions 

of 162 pounds per day, or about 0.08 tons per day in California. Nonaerosol Grill 

Cleaner products have estimated VOC emissions of 479 pounds per day, or about 

0.24 tons per day in California. Although not shown, the sales-weighted average VOC 

content is 8.7 percent by weight for aerosol products and 1.4 percent by weight for 

nonaerosol products. 

Product Use and Marketing: 

Oven or Grill Cleaner products are sold through a variety of sales outlets including 

supermarkets, home centers, grocery stores, drug stores, and by mass merchandisers. 

Oven or Grill Cleaner products are also sold to commercial or institutional users through 

distributors or through direct sales by the manufacturer. 

Products are used to remove food soils from household, commercial, and industrial 

ovens and grills, as well as, other surfaces where polymerized food soils have 

accumulated. At normal cooking temperatures organic deposits of fats, greases, oils, 

proteins, and carbohydrates are converted into a polymerized film or mass of charred 

material. For removal, such polymerized or baked-on deposits require use of Oven or 

Grill Cleaner products. Collectively, as used here, we are employing the term 

“polymerized food soils” to describe the types of soils an Oven or Grill Cleaner product 

would be used to remove. Inorganic deposits of water, including insoluble salts of 

calcium, magnesium, iron, and manganese also require use of an Oven or Grill Cleaner 

to remove them. These deposits reduce heating efficiency, increase fire hazards and 

cause unpleasant odors. Dirty ovens or grills also distort the food's flavor and aroma 

and can promote or support the growth of microorganisms that can contaminate food or 

other materials or surfaces. 

Product labels, especially those for caustic products, include precautionary 

recommendations to use protective eye goggles, and to wear long sleeves and rubber 

gloves when using the product. Directions for using products recommend protecting 

surfaces from overspray and to apply product to the bottom of the oven, then sides and 
Technical Support Document Chapter VII - 89 

top evenly. Labels also indicate Oven or Grill Cleaner products can be used in warm or 

cold ovens. Following application the product should dwell for a period of time prior to 

wiping surface to remove materials. 

Nonaerosol products are sold as ready-to-use (RTU) pump sprays or as liquid 

concentrates. Products can be applied using a brush, sponge, grill pad, or pump spray. 

Applying the product using a pump spray allows the product to be applied to vertical, 

overhead or inclined surfaces. For this reason, many liquid concentrate products 

include dilution instructions for use in re-usable pump spray bottles. 

Product Formulation: 

Oven or Grill Cleaner products use compounds that provide alkalinity for saponification 

(alkali reacts with fats to form soluble soap) along with solvents and surfactants to 

remove polymerized food soils. Solvents penetrate greases and assist in 

depolymerizing reacted food soils. When surfactants are present above the critical 

micelle concentration, they can act as emulsifiers that will allow a compound that is 

normally insoluble in water to dissolve. 

The primary alkaline ingredients in Oven or Grill Cleaner products continue to be the 

caustic alkalis, sodium and potassium hydroxide. These compounds react with fats, 

partially converting them into their sodium or potassium salts which are water-soluble 

and easily removable. Products often contain 30 percent or more of sodium or 

potassium hydroxide. 

Typical reported VOC solvents include 2-butoxyethanol, monoethanolamine, isopropyl 

alcohol, ethyl alcohol, amino methyl propanol, and d-limonene. Typical reported LVPVOC solvents include diethylene glycol monobutyl ether, tripropylene glycol methyl 

ether, diethanolamine, and triethanolamine. Additional reported ingredients include 

sodium xylene sulfonate, alkylphenol ethoxylates, ethoxylated alcohols, tetrapotassium 

pyrophosphate, metallic carbonates, and metasilicates. 

Proposed VOC Limit and Compliance: 

We are proposing to incorporate grill cleaning products into the Oven or Grill Cleaner 

category. To allow the previously unregulated grill cleaner products the necessary time 

to reformulate, proposed subsection 94509(r) would specify that the VOC limits do not 

apply to these products until December 31, 2012. 

Nonaerosol Oven Cleaner products are currently subject to a VOC limit of 1 percent by 

weight. When this limit was approved reported products relied on low or non-VOC 

caustic technologies. We have since learned of less harsh technologies introduced to 

provide alternatives to caustic products. To accommodate the use of these 

technologies we are proposing to increase the current VOC limit to 4 percent by weight 

for nonaerosol Oven or Grill Cleaner products. To expedite providing this alternative, as 

proposed, the limit revision would become effective when the amendments become 
Technical Support Document Chapter VII - 90 

legally effective. As shown in Table VII-16, this proposal results in a small emission 

reduction shortfall of 240 pounds per day, or about 0.1 tons per day. However, other 

reductions from this proposal would offset this change. To arrive at the amount of VOC 

increase resulting from the proposal, data from the Oven Cleaner products surveyed in 

2003 were considered. 

Table VII-16 

Oven or Grill Cleaner Proposal 

Product Form

Proposed VOC 

Limit 

(weight percent)

Number of

Complying 

Products

Complying 

Market Share 

(percent)

2012 Emissions 

Reductions 

(pounds per day) 

Aerosol 8 18 87 > 0 

Nonaerosol 4 81 99 - 240* 

* Previously regulated oven cleaning products incorporated to arrive at the emissions increase. 

 Some of these oven cleaning products will reformulate from 1 percent VOC by weight to 4 percent 

 VOC by weight. 

Table VII-16, also show 87 percent of the market already complies with the aerosol 

VOC limit of 8 percent. For nonaerosol products, 99 percent of the market complies 

with the proposed 4 percent VOC limit. We expect the few noncomplying products to 

reformulate using ingredients less harsh than the caustic alkalis sodium or potassium 

hydroxide. Reformulated products would likely reformulate using LVP-VOC glycol 

ethers, ethanolamines, ethoxylated alcohols, metallic carbonates, and meta-silicates. 

Proposal to Prohibit Use of Alkylphenol Ethoxylate Surfactants: 

Alkylphenol ethoxylate surfactants, in particular the octylphenol and nonylphenol 

ethoxylates, are known to be toxic to aquatic species. We are aware that some Oven or 

Grill Cleaner products contain these compounds. Because of this, ARB staff consulted 

with State Water Resources Control Board (SWRCB) staff to determine if continued use 

of these compounds could adversely affect water quality. Information provided to 

SWRCB staff indicates that alkylphenol ethoxylates were found in measurable 

concentrations in the State’s receiving waters. Therefore, SWRCB staff expressed 

concern that any potential increased use of alkylphenol ethoxylate surfactants could 

adversely impact aquatic species (SWRCB, 2010a; SWRCB, 2010b; SCCWRP, 2010; 

and SFEI, 2010). In light of this finding, we are proposing a CEQA mitigation measure 

to ensure that use of alkylphenol ethoxylate surfactants does not occur as products 

reformulate. As proposed, section 94509(m)(3) would preclude use of alkylphenol 

ethoxylate surfactants in Oven or Grill Cleaner products effective December 31, 2012. 

Further information on this proposal, as well as the need, is contained in Chapters VI 

and IX. 
Technical Support Document Chapter VII - 91 

I. Special-purpose Lubricant

The Special-purpose Lubricant category is not currently regulated. We are proposing to 

define “Special-purpose Lubricant” as a lubricant designed or labeled as: a cutting or 

tapping oil; an anti-seize product; an open gear, chain or wire lubricant; and products 

which claim to prevent and/or inhibit corrosion that makes a lubricating claim. The 

“Special-purpose Lubricant” category would not include the other regulated categories 

“Multi-purpose Lubricant,” “Silicone-based Multi-purpose Lubricant,” “Penetrant,” 

products designed and labeled exclusively to release manufactured products from 

molds, and products designed or labeled to provide lubricity solely by depositing a thin 

film of graphite, molybdenum disulfide (“moly”), or polytetrafluoroethylene or closely 

related fluoropolymer (“teflon”) on surfaces. 

Special-purpose Lubricants are used in household, automotive, institutional, and 

industrial settings on metal parts to reduce friction, heat and wear between moving 

parts. Products that lubricate may also secondarily function to inhibit rust. 

Table VII-17 below summarizes the sales and emissions from Special-purpose 

Lubricant based on the results of the 2006 Survey (ARB, 2007e). Data have been 

grown, by population, to 2010. As shown, Special-purpose Lubricant products have 

category sales of 29,600 pounds per day in California. 

Table VII-17 

Special-purpose Lubricant 

Product Form 

Number of 

Products 

2010 

Category Sales 

(pounds per day) 

2010 Market-Adjusted 

VOC Emissions 

(pounds per day) 

Aerosol 168 1,413 512 

Nonaerosol 224 28,187 365 

As shown in Table VII-17, Special-purpose Lubricant products are sold in both the 

aerosol and nonaerosol forms, with estimated VOC emissions of 877 pounds per day, 

or about 0.44 tons per day in California. Although not shown, the sales-weighted 

average VOC content of the aerosol and nonaerosol products are 36 and 1 percent by 

weight, respectively. 

Product Use and Marketing: 

Special-purpose Lubricant products are used by professionals and do-it-yourselfers in 

specific applications. These products are used on tools, all kinds of machinery, 

construction equipment, automotive and marine engines, and parts which need 

lubrication in order to function properly. They are also used for maintenance to reduce 

wear and extend the usable life of the substrate being lubricated. 
Technical Support Document Chapter VII - 92 

Special-purpose Lubricant products have specific purposes, for example, cutting and 

tapping oils. These oils are used on drills, saws, and taps to extend tool life. Machining 

operations (e.g., sawing, milling, tapping, drilling, shaping, etc.) use various cutting oils 

depending on material. Besides lubricating, cutting and tapping oils also aid the cutting 

process by cooling or removing the heat generated due to friction between the tool and 

the surfaces. It can be a product which leaves a film after application for lubrication, or 

it may also be a fluid which continuously flows onto the moving parts to reduce heat and 

friction and improve tool efficiency. 

Anti-seize lubricant products are typically used on machinery where seizing, fretting or 

galling of parts can be a problem due to extreme temperature and/or pressure 

conditions. Application of these products is especially important in environmentally 

adverse conditions such as high humidity and salinity, and acidic atmospheres. Antiseize lubricant products contain powdered metallic additives such as zinc, copper, 

aluminum, and nickel or nonmetallic materials such as molybdenum disulfide, graphite, 

zinc oxide or calcium oxide. These additives enable the product to prevent the metal 

parts from seizing. A combination of these solid lubricating agents results in different 

high temperature limits and lubricities to suit specific needs. 

In some applications rust preventative lubricant products are used to improve corrosion 

resistance to allow parts to be subsequently disassembled in a variety of settings. 

These formulas are also used to break down rust and corrosion, to free plumbing, 

rusted bolts and other fittings, release jammed or locked mechanisms, and corroded 

parts. Typically, these lubricants form a thin, anti-rust, nondrying film by displacing 

moisture which protects various metal surfaces. 

Open gear, chain or wire lubricants penetrate, protect and preserve open gears, chains, 

bars, wire ropes, cables, hoists, pulleys, conveyors, forklifts, elevators, overhead door 

drives with minimum "throw-off" from centrifugal force. 

Some products proposed for inclusion in the Special-purpose Lubricant category also 

makes claims that they are suitable in situations where there may be direct or indirect 

contact with food. These ‘food grade’ lubricants would be included in the category. 

Special-purpose Lubricant products are sold primarily in hardware stores, automotive 

parts stores, and industrial supply houses. These products are also sold through 

distributors or through direct sales by the manufacturer to industrial or institutional 

users. 

Product Formulation: 

As reported in the 2006 Survey, Special-purpose Lubricant product formulations are 

typically composed of petroleum base oils. Petroleum distillates such as naphthenic 

and aliphatic hydrocarbons serve as the carrier fluid. Limited use of trichloroethylene, 

methylene chloride, or perchloroethylene was reported. 
Technical Support Document Chapter VII - 93 

The VOC content of products in this category ranges from 0 to 100 percent by weight 

for both aerosol and nonaerosol products, with a sales-weighted average VOC content 

of 36 and 1 percent by weight for aerosol and nonaerosol products, respectively. 

Special additives such as PTFE, greases, and powdered metals are sometimes used to 

accomplish the lubrication, depending on the application. 

For aerosol products, hydrocarbon propellant (such as propane, butane, 

iso-butane) is most often used. In some cases carbon dioxide (CO2) is used. 

Proposed VOC Limit and Compliance: 

The proposed VOC limit for Special-purpose Lubricant products is 25 percent by weight 

for aerosols and 3 percent by weight for nonaerosols, effective December 31, 2012. As 

shown in Table VII-18, using emissions adjusted to 2012, the proposed limits for the 

category will result in an estimated emission reduction of 461 pounds per day, or about 

0.23 tons per day statewide. 

Table VII-18 

Special-purpose Lubricant Proposal 

Product Form

Proposed VOC 

Limit 

(weight percent) 

Number of

Complying 

Products

Complying 

Market Share 

(percent)

2012 Emissions 

Reductions 

(pounds per day)**

Aerosol 25 64 47 207 

Nonaerosol 3 166 97 254 

Table VII-18 also shows that 47 percent of the aerosol market currently complies with 

the proposed 25 percent VOC limit, and 97 percent of the nonaerosol market complies 

with 3 percent VOC limit. Complying aerosol and nonaerosol products are already sold 

in each type of lubricant proposed for consolidation into the Special-purpose Lubricant 

category. 

Staff has determined that reformulation to the proposed limits is technologically and 

commercially feasible. As shown in Table VII-18, the majority of nonaerosol products in 

this category already meet the proposed 3 percent limit. Additionally, the 47 percent 

complying market share demonstrates that aerosol products with VOC content at or 

below 25 percent are already available and well-accepted by consumers. 

Reformulation options that can be used by manufacturers to meet the proposed limit 

include using LVP-VOC hydrocarbon solvents and acetone. Acetone is currently used 

in several Special-purpose Lubricant product formulations at a level of 10 to 50 percent. 

Another reformulation option is to use a non-VOC propellant such as CO2 as a 

replacement for hydrocarbon propellants. CO2 may also be used in combination with 

hydrocarbon propellants along with LVP-VOC or non-VOC solvents. However, because 
Technical Support Document Chapter VII - 94 

CO2 typically only constitutes about 2 to 5 percent of the overall formulation, additional 

reformulation techniques must be used in order to achieve compliance. 

We expect that manufacturers will meet the proposed limit by using formulation 

technologies similar to complying products. 

Proposal to Prohibit Use of Certain TAC Solvents: 

We are proposing a CEQA mitigation measure to prohibit the use of the chlorinated 

TAC solvents methylene chloride, perchloroethylene, and trichloroethylene. The 

prohibition of these three solvents is necessary, particularly for methylene chloride and 

perchloroethylene, because they are exempt VOCs and could be used in reformulated 

products without ‘counting’ toward VOC content. The prohibition would become 

effective on December 31, 2012. Survey data show that the proposed limits can be met 

without the use of these compounds. More information on this proposal is contained in 

Chapter IX, Environmental Impacts, section E. 

Proposed GWP Limit: 

No compounds with GWP values above 150 were reported in the 2006 Survey for this 

category. However, to ensure that use of compounds with higher GWP values does not 

begin as products reformulate to comply with the proposed VOC limits, we are 

proposing a GWP limit of 150 for any chemical compound used in Special-purpose 

Lubricant products, effective December 31, 2012. While this proposal would allow use 

of the non-VOC propellant, HFC-152a, we believe other reformulation options are more 

likely. The proposed limit would not apply to any chemicals present as contaminants, 

which in aggregate are 0.1 percent by weight or less. This limit is proposed as a 

mitigation measure under CEQA (see Chapter IX, Environmental Impacts, section E). 

The proposed limit is contained in section 94509(n). 

Issues: 

1. Issue: Every kind of Special-purpose Lubricant cannot be accommodated 

 by one VOC limit. 

Response: All subcategories of Special-purpose Lubricant have been 

thoroughly evaluated and the proposed VOC limits have been found to be 

technologically and commercially feasible. Complying products were available in 

every surveyed subcategory in aerosol and nonaerosol forms. 

J. Spot Remover (Dry Clean Only) 

In the Consumer Products Regulation, “Spot Remover” means any product labeled to 

clean localized areas, or remove localized spots or stains on cloth or fabric such as 

drapes, carpets, upholstery, or clothing, that does not require subsequent laundering to 

achieve stain removal. “Dry Cleaning Fluid,” “Laundry Prewash,” and “aerosol products 

labeled solely for gum removal” are excluded from the definition of “Spot Remover.” 
Technical Support Document Chapter VII - 95 

Spot Remover products that are used at dry cleaners and other commercial launderers 

for spot-cleaning and stain removal have been considered "Dry Cleaning Fluid" 

products. Therefore, these products have not been regulated under the category of 

"Spot Remover." 

Spot Remover products were first regulated in 2001, when VOC limits of 25 percent by 

weight for the aerosol form and 8 percent by weight for the nonaerosol forms were 

adopted. In 2008, the Board approved amendments to lower the VOC limit for the 

aerosol form of Spot Remover products to 15 percent by weight, and the nonaerosol 

form to 3 percent VOC by weight. A prohibition on use of the TACs methylene chloride, 

perchloroethylene, and trichloroethylene, was also approved. These requirements are 

to become effective December 31, 2010 (ARB, 2009d).

To evaluate whether the exemption for Spot Remover (Dry Clean Only) products was 

still necessary, companies that sold spotting chemicals to dry cleaning establishments, 

or that sold household “dry cleaning” products, were surveyed for their 2008 California 

sales. The survey was titled, “2008 Survey Update for Dry Clean Only Spot Removers” 

(2008 Survey Update). The survey data review indicates that the exemption is no 

longer necessary. Therefore, ARB staff is proposing to remove the exclusion. This 

would mean that Spot Remover (Dry Clean Only) products would be subject to the VOC 

limits already in place. 

Spot Remover (Dry Clean Only) products are also referred to in this section as “spotting 

agents,” “spotters,” or “spotting chemicals.” These products are formulated to remove 

localized spots or stains on fabrics labeled for “dry clean only,” or on “S-coded fabrics,” 

such as clothing, rugs, curtains, or other similar items that can be cleaned by a 

commercial dry cleaning establishment or professional laundry facility. A few ‘home 

use’ products are available to the general public. “S-coded fabrics” refer to fabrics 

specified by the Joint Industry Fabric Standards Committee to be cleaned only with 

water-free spot cleaning products. Spotting chemicals may be intended for one type of 

stain, or for several (ARB, 2008a; and SCRDC, 2010). Industry separates spotting 

agents into two main categories: “dry-side” and “wet-side” (U.S. EPA, 1998b). 

As their names imply, dry-side spotting agents are for garments and items that would be 

washed with nonaqueous solvents, i.e., intended for a typical nonaqueous, solventbased dry cleaning machine such as a perchloroethylene or hydrocarbon system. Dryside spotters are for removing oil-based stains and spots, including but not limited to 

paint, grease, tar, and nail polish. 

Wet-side spotting agents are for stains that are water-based, including but not limited to 

perspiration, grass stains, blood, certain foods or beverages, mustard and other plantbased stains. Some spotters are for both wet and dry-side stains. 

To clarify the products that would be included or excluded from the definition of Spot 

Remover, staff is proposing modifications to three definitions. The proposed changes 

are presented in strikeout/underline format for ease of reviewing the edits. 
Technical Support Document Chapter VII - 96 

1. Proposed modification to the definition of Spot Remover: 

“Spot Remover” means any product labeled to clean localized areas, or remove 

localized spots or stains on cloth or fabric such as drapes, carpets, upholstery, or 

clothing, that does may or may not require subsequent laundering to achieve 

stain removal. “Spot Remover” includes spotting agents used by commercial 

launderers and dry cleaners. “Spot Remover” does not include “Dry Cleaning 

Fluid,” “Laundry Prewash,” or aerosol products labeled solely for gum removal. 

This modification is necessary to clarify that spotters used at commercial launderers 

and dry cleaners are considered "Spot Remover" products. 

2. Proposed modification to the definition of Dry Cleaning Fluid: 

 “Dry Cleaning Fluid” means any non-aqueous liquid product nonaqueous solvent 

that is (A) used in dry-cleaning machines at commercial dry cleaners or used by 

commercial businesses that clean fabrics such as draperies at the customer’s 

residence or work place; and (B) is designed and labeled exclusively to clean for 

use on: (1) fabrics which are labeled “for dry clean only,” such as clothing or 

drapery; or (2) “S-coded” fabrics. “Dry Cleaning Fluid” includes, but is not limited 

to, those products used by commercial dry cleaners and commercial businesses 

that clean fabrics such as draperies at the customer’s residence or work place.

“Dry Cleaning Fluid” does not include “Spot Remover” or “Carpet/Upholstery 

Cleaner.” For the purposes of this definition, S-coded fabric means an 

upholstery fabric designed to be cleaned only with water-free spot cleaning 

products as specified by the Joint Industry Fabric Standards Committee.” 

This modification is intended to clarify that “Dry Cleaning Fluid” means only the solvent 

used in dry cleaning machines. Spotting chemicals would no longer be considered "Dry 

Cleaning Fluid" products. 

3. Proposed modification to the definition of Laundry Prewash: 

“Laundry Prewash” means a product that is designed for application to a fabric 

prior to laundering in a wet-cleaning process, and that supplements and 

contributes to the effectiveness of laundry detergents and/or provides specialized 

performance. 

This modification is intended to clarify that a “Laundry Prewash” is a product used in a 

cleaning process that uses water as the solvent. 

Table VII-19 below summarizes the sales and emissions, grown to 2010, for Spot 

Remover (Dry Clean Only) products (ARB, 2009e). Total category sales are about 

860 pounds per day, or 0.43 tons per day in California. 
Technical Support Document Chapter VII - 97 

Table VII-19 

Spot Remover (Dry Clean Only) *

Product Form 

Number of 

Products 

2010 

Category Sales 

(pounds per day) 

2010 Market-Adjusted 

VOC Emissions 

(pounds per day) 

Aerosol ** < 5 < 10 < 10 

Nonaerosol 49 860 350 

* Based on 2008 Dry Clean Only Spot Remover Survey (ARB, 2009e). 

** Data estimated to preserve confidentiality. 

As shown in Table VII-19, Spot Remover (Dry Clean Only) products are sold in both the 

aerosol and nonaerosol forms, with total estimated VOC emissions of 350 pounds per 

day, or about 0.17 tons per day in California. Although not shown, the sales-weighted 

average VOC content for the aerosol and nonaerosol Spot Remover (Dry Clean Only) 

product forms is about 25 and 40 percent by weight, respectively. 

Product Use and Marketing: 

Spot Remover (Dry Clean Only) products are used by commercial laundering or dry 

cleaning establishments, for cleaning localized spots, stains, and soiled areas on items 

which include, but are not limited to, articles of clothing labeled “dry clean only;” delicate 

fabrics, leather items such as jackets, belts, and purses; window coverings, and rugs. 

 

Articles that can be laundered are cleaned in a dry cleaning or wet-cleaning machine 

after “pre-spotting” with the spot remover product. Pre-spotting involves the article 

being placed on the establishment’s “spotting board,” where the spotting chemical is 

applied to the stain or spot, the area may be agitated with a brush or spatula, then the 

article may be left to sit a few minutes before laundering in the dry cleaning machine or 

washing machine. The spotting chemical is not allowed to dry before the article goes 

into the machine for laundering. 

If an article is unsuitable for laundering, such as a purse or belt, it would undergo the 

same procedure as an article that still has a spot or stain after the machine cleaning, 

called “post-spotting.” Post-spotting is a procedure where the spotting chemical is 

applied to a spot or stain, agitated with a brush or spatula, then may be blotted dry, or 

rinsed with a solvent, water, or steam, if appropriate. The article is then air-dried. The 

spotting chemical or rinse is intended to evaporate after use without leaving a residue. 

The article does not then need to be re-cleaned after the post-spotting application (ARB, 

2009e). 

Spot Remover (Dry Clean Only) products are typically sold to dry cleaning 

establishments and professional laundering facilities through the products’ 

manufacturers and their distributors. Marketing is done through catalogs, trade 

magazines, and on the Internet. Only a few products are intended for the household 

market. 
Technical Support Document Chapter VII - 98 

Product Formulation: 

Dry-side spotting agents are mainly formulated with nonaqueous solvents, meaning 

they have little or no water content. In the 2008 Survey Update, the most common 

reported ingredients include trichloroethylene, glycol ethers, amyl and butyl acetate, 

methyl isobutyl ketone, and VOC hydrocarbon solvents. A small amount of methylene 

chloride was reported. Some complying dry-side spotting agents contain LVP-VOC 

hydrocarbon solvents and LVP-VOC glycol ethers. 

Wet-side spotting agents are generally water-based products containing ingredients 

such as glycol ethers, surfactants, enzymes, and various inorganic cleaning 

compounds. Ingredients vary depending on the types of spots and stains to be 

removed, although many products are formulated for general use to address several 

types of stains. A common VOC ingredient is ethylene glycol monobutyl ether which is 

used to treat many oil-based and water-based stains. LVP-VOC glycol ethers are also 

used (ARB 2009e). 

Many complying products reported in this category were wet-side spotting agents. 

Technically these water-based products do not meet the definition of “Dry Cleaning 

Fluid.” From this observation, we infer there has already been a shift in the market due 

to phase-out of perchloroethylene from dry cleaning operations, as required by the 

Airborne Toxic Control Measure for Emissions of Perchloroethylene from Dry Cleaning 

and Water-Repelling Operations (ARB, 2007b). 

The aerosol products were consistent in formulation with the Spot Remover products 

that are currently regulated. The reported emissions from the aerosol products were 

negligible compared to the nonaerosol products (ARB, 2009e). 

The reported nonaerosol products were generally liquids dispensed from a jar, can, 

tube, or squeeze-tube. Most low-VOC products were water-based, and formulations 

included LVP-VOC ingredients, such as surfactants and LVP-VOC glycol ethers, and 

inorganic ingredients. Some products were sold in concentrated liquid form. 

Specialized products also exist in this category. For example, products containing nonVOC inorganic acids or bases are used to remove rust and certain water-based stains 

(ARB, 2009e). 

Proposed Limits and Compliance: 

ARB staff is proposing to incorporate Spot Remover (Dry Clean Only) products into the 

currently regulated Spot Remover category. As such, aerosol and nonaerosol spotting 

products would need to comply with the 15 percent by weight and 3 percent by weight 

VOC limits, respectively. These VOC limits for Spot Remover products are to become 

effective December 31, 2010. To provide industry with the necessary time to 

reformulate the newly added products to meet the limits, we believe extending the 

effective date is appropriate; it would be difficult, from an enforcement perspective, to 

discern currently regulated products from those being newly added. Therefore, we are 
Technical Support Document Chapter VII - 99 

proposing to extend the effective date for two years, until December 31, 2012. This 

proposal would result in delaying 573 pounds per day, or about 0.29 tons per day of 

VOC emission reductions until the end of 2012. 

As shown in Table VII-20, using emissions adjusted to 2012, the proposed limits for the 

category will result in an estimated emission reduction of 340 pounds per day, or about 

0.17 tons per day statewide. 

Table VII-20 

Spot Remover (Dry Clean Only) Proposal *

Product Form

Proposed 

VOC Limit 

(weight percent)

Number of

Complying 

Products

Complying 

Market Share 

(percent)

2012 Emissions 

Reductions 

(pounds per day) 

Aerosol ** 15 < 5 < 5 < 3 

Nonaerosol 3 16 46 340 

* Based on 2008 Dry Clean Only Spot Remover Survey Update (ARB, 2009e). 

** Data estimated to preserve confidentiality. 

The staff report for the 2008 CONS-II amendments provides information on 

commercially and technologically feasible reformulation options for aerosol Spot 

Remover (Dry Clean Only) products to meet the 15 percent by weight VOC limit (ARB, 

2008a). Non-VOC propellant options are available, which would allow reformulated 

products to contain up to 15 percent by weight VOC solvent such as ethylene glycol 

monobutyl ether. A combination of VOC hydrocarbon propellant with LVP-VOC 

solvents, inorganic ingredients, or exempt compounds is another viable alternative to 

reformulate dry-side spotting agents. 

The proposed VOC limit for nonaerosol Spot Remover (Dry Clean Only) products 

would allow up to 3 percent by weight VOC ingredients such as ethylene glycol 

monobutyl ether. The balance would be primarily water along with LVP-VOC solvents, 

surfactants, enzymes, inorganic compounds, or other exempt compounds 

(ARB, 2009e). In its report on alternative spotting chemicals tested in dry cleaning 

establishments, the Institute for Research and Technical Assistance found several 

nonaerosol formulations that were effective and met the proposed 3 percent by weight 

VOC limit (IRTA, 2009). 

Additionally, at the end of 2010, prohibitions on the use of the TACs methylene 

chloride, perchloroethylene, trichloroethylene were to become effective. The newly 

added spotting products would also be subject to these prohibitions. The proposal to 

extend the effective date to December 31, 2012, would apply to these provisions as 

well. 
Technical Support Document Chapter VII - 100 

Proposal to Prohibit Use of Certain TAC Solvents: 

“Spot Remover” products that are currently regulated are subject to a prohibition on use 

of methylene chloride, perchloroethylene, and trichloroethylene. We are proposing to 

prohibit the use of the chlorinated TAC solvents methylene chloride, perchloroethylene, 

and trichloroethylene in these newly added products. The prohibition of these three 

solvents is necessary, particularly for methylene chloride and perchloroethylene, 

because they are exempt VOCs and could be used in reformulated products without 

‘counting’ toward VOC content. The provision would become effective on 

December 31, 2012. Staff’s evaluation of the 2008 Survey Update data show 

formulation technologies that do not contain methylene chloride, perchloroethylene, or 

trichloroethylene are readily available, and are not needed to comply with the proposed 

standard. More information on this proposal is contained in Chapter IX, Environmental 

Impacts, section E. 

Proposed GWP Limit: 

A small amount of hydrochlorofluorocarbon-141b (HCFC-141b) was reported. 

However, we have since learned that products containing this compound are no longer 

sold in California. Other than HCFC-141b, no compounds with GWP values at or above 

150 were reported in the 2008 Survey Update for this category. However, to ensure 

that use of compounds with higher GWP values does not begin as products reformulate 

to comply with the proposed VOC limits, we are proposing a GWP limit of 150 for any 

chemical compound used in Spot Remover (Dry Clean Only) products, effective 

December 31, 2012. While this proposal would allow use of the non-VOC propellant, 

HFC-152a, we believe other reformulation options are more likely. The proposed limit 

would not apply to any chemicals present as contaminants, which in aggregate are 0.1 

percent by weight or less. This limit is proposed as a mitigation measure under CEQA 

(see Chapter IX, Environmental Impacts, section E). The proposed limit is contained in 

section 94509(n). 

Issues: 

1. Issue: Some dry cleaning establishments are using spotting chemicals that 

contain the solvent normal-propyl bromide (n-PB). The Bay Area Air Quality 

Management District banned this chemical from dry cleaning spotters in its 

jurisdiction, and ARB should do the same because of n-PB’s potential 

reproductive and neurotoxic effects. 

 Response: The chemical n-PB is a VOC. As such, ARB staff has determined 

that the VOC limits are sufficiently low such that use of n-PB, if any, will be 

negligible. Therefore, a prohibition is not needed. 
Technical Support Document Chapter VII - 101 

K. Wasp or Hornet Insecticide (aerosol)

“Wasp or Hornet Insecticide” means any insecticide product that is designed for use 

against wasps, hornets, yellow jackets or bees by allowing the user to spray from a 

distance a directed stream or burst at the intended insects, or their hiding place. The 

Wasp or Hornet Insecticide category does not include products that are used to repel 

these insects. 

Aerosol Wasp or Hornet Insecticide products are currently subject to a 40 percent by 

weight VOC limit, which has been in effect since January 1, 2005. Wasp or Hornet 

Insecticide products were first regulated under the “Midterm-measures II” amendments 

approved in October 1999. A description of these products is included in the staff report 

for that rulemaking (ARB, 1999). 

The 2006 Survey provides the basis for our determination that it is technologically and 

commercially feasible to further reduce VOCs from these products. Based on these 

data, staff is proposing to lower the VOC limit for aerosol Wasp or Hornet Insecticide 

products to 10 percent by weight. We are also proposing to change the category name 

from “Wasp and Hornet Insecticide” to “Wasp or Hornet Insecticide” and limit the use of 

compounds with higher GWP values. 

Product Use and Marketing: 

Table VII-21 summarizes the sales and emissions from aerosol Wasp or Hornet 

Insecticide products (ARB, 2007e). The data have been grown, by population, to 2010. 

As shown in Table VII-21, the 56 aerosol Wasp or Hornet Insecticide products reported 

have estimated category sales of 6,112 pounds per day in California. 

Table VII-21 also shows the 2010 market-adjusted VOC emissions are 618 pounds per 

day, or about 0.31 tons per day in California. Although not shown, the sales-weighted 

average VOC content for this category is 10.1 percent by weight, excluding fragrance. 

Table VII-21 

Wasp or Hornet Insecticide 

Product Form 

Number of 

Products 

2010 

Category Sales 

(pounds per day) 

2010 Market-Adjusted 

VOC Emissions 

(pounds per day) 

Aerosol 56 6,112 618 

Product Use and Marketing:

Aerosol Wasp or Hornet Insecticide products are used by household consumers and 

institutional consumers, such as utility or telecommunication company’s workers. These 

products must enable the user to knockdown and kill the insects rapidly to avoid attack. 
Technical Support Document Chapter VII - 102 

Most products dispense the insecticide in a liquid jet stream while a few produce a foam 

which blankets the insect or nest. 

Wasp or Hornet Insecticide products can be purchased through supermarkets, drug 

stores, discount stores, mass merchandisers, hardware stores, garden and landscape 

supply stores, warehouse stores, and home centers. Consumers may also purchase 

products through catalog sales and the Internet. 

Wasp or Hornet Insecticide products sold within California must be registered with 

California’s DPR in addition to being FIFRA registered. These registrations are 

designed to thoroughly evaluate the insecticide product to ensure it meets both federal 

and State requirements to protect public health and the environment. As part of the 

registration process, the efficacy data are reviewed to validate the spectrum of activity. 

The Consumer Products Regulation allows FIFRA registered products an additional 

year for compliance to allow the necessary time to complete the registration. 

Control of wasps or hornets is sometimes difficult because if they are not killed quickly 

they may become agitated and attack the user. The object is to kill all of the wasps or 

hornets in the nest quickly and completely. The ingredients in aerosol Wasp or Hornet 

Insecticide products are similar to crawling bug insecticides. However, aerosol Wasp or 

Hornet Insecticide products have unique propellant and aerosol hardware systems to 

produce a jet-type spray that reaches from ten to over twenty feet. This allows the user 

to spray the insecticide into inaccessible nests located in areas such as rooftops or 

trees. Products available can deliver the insecticides with a 22 foot foam blast. This 

allows users to stand back and “lock” the wasps or hornets inside their nest with a 

blanket of foam. It is recommended that users wear protective clothing and attempt to 

eradicate wasps or hornets in early morning or late afternoon/evening when the insects 

are at rest (ARB, 1997b; CSPA, 2010a; Claire, 2010). 

Product Formulation: 

Pesticide products contain both "active" and "inert" ingredients. The terms "active 

ingredient" and "inert ingredient" have been defined by FIFRA since 1947. The 

U.S. EPA defines an active ingredient as one that prevents, destroys, repels or 

mitigates a pest, or is a plant regulator, defoliant, desiccant or nitrogen stabilizer. By 

law, the name and percentage of the active ingredient must be identified and displayed 

on the product label. 

An inert ingredient is defined by U.S. EPA as any substance (or group of structurally 

similar substances if designated by U.S. EPA), other than an active ingredient, which is 

intentionally included in a pesticide product. Inert ingredients play a key role in the 

effectiveness of a pesticide product. For example, inert ingredients may serve as a 

solvent, allowing the pesticide's active ingredient to be delivered to the target pest. In 

some instances, inert ingredients are added to extend the pesticide product's shelf-life 

or to protect the pesticide from degradation due to exposure to sunlight. Pesticide 

products can contain more than one inert ingredient, but federal law does not require 
Technical Support Document Chapter VII - 103 

that these ingredients be identified by name or percentage on the label. Only the total 

percentage of inert ingredients is required to be on the pesticide product label 

(U.S. EPA, 2003b; U.S. EPA, 2010a). 

In this rulemaking, our proposal does not directly affect the active ingredients to be 

used. The proposal is intended to only affect the use of inert ingredients that are VOCs 

and compounds with higher GWP values in Wasp or Hornet Insecticide products. 

Active Ingredients: 

As shown on product labels, the active ingredients make up only a small portion of 

Wasp or Hornet Insecticide product formulations. Typically about 1 percent by weight of 

active ingredients is used. Based on data from the 2006 Survey, the active ingredients 

found in Wasp or Hornet Insecticide products are pyrethroids and the synergists 

piperonyl butoxide, and N-octyl bicycloheptene dicarboxmide (MGK-264). According to 

U.S. EPA, the synergists have no pesticidal effects of their own but enhance the 

effectiveness of pyrethrins and pyrethroids (U.S. EPA, 2010b). 

Inert Ingredients: 

The bulk of the Wasp or Hornet Insecticide product formulation consists of the inert 

ingredients, such as propellants, solvents, and co-solvents. The propellants are 

typically hydrocarbon blends or compressed gases such as carbon dioxide (CO2). 

Solvents and co-solvents include VOC and LVP-VOC petroleum distillates, water, 

emulsifiers, surfactants, or corrosion inhibitors (ARB, 2007e; ARB, 1997b; AgrEvo, 

2010). 

Emulsifiers, surfactants, and corrosion inhibitors are typically present in small amounts 

in the product formulation. Some inert ingredients are used to solubilize the actives, 

and aid the mixing of actives to create a homogeneous liquid that can be sprayed. 

Solvents and co-solvents may be used to increase the vapor pressure in a product, and, 

along with the aerosol container, valve, and nozzle, to control spray pattern. 

The most frequently used inert ingredients reported in the 2006 Survey include water, 

mineral spirits, propane, propylene glycol n-butyl ether, n-butane, petroleum distillates 

and synthetic paraffinic hydrocarbons. LVP-VOC glycols, such as dipropylene glycol 

and propylene glycol, were also reported in the 2006 Survey for some of the Wasp or 

Hornet Insecticides products. The majority of the products did not report the use of 

fragrance mixtures. 

Propellants: 

Propellant blends used vary depending on the formulation. According to the 2006 

Survey, propellant content in Wasp or Hornet Insecticide products ranged from 1 

percent to about 10 percent of product weight. The propellants used include 

hydrocarbon blends of n-butane, iso-butane, and propane. Over 70 percent of the 
Technical Support Document Chapter VII - 104 

product formulations reported the use of CO2. No VOC exempt propellants were 

reported. 

Proposed VOC Limit and Compliance: 

The proposed VOC limit for aerosol Wasp or Hornet Insecticide products is 

10 percent by weight, effective December 31, 2013. As shown in Table VII-22, the 

proposed 10 percent by weight VOC would result in emission reductions of 286 pounds 

per day, or about 0.14 tons per day, statewide in 2014. The emission reduction is 

estimated for 2014 because products requiring FIFRA registration are given an extra 

year, as specified in section 94509(d), from the proposed effective date to comply. This 

reduction, although important to overall air quality, will not occur within the timeframe to 

be credited toward the current SIP commitment. 

Table VII-22 

Wasp or Hornet Insecticide Proposal 

Product Form

Proposed VOC 

Limit 

(weight percent)

Number of

Complying 

Products

Complying 

Market Share 

(percent)

2014 Emissions 

Reductions 

(pounds per day)

Aerosol 10 38 60 286 

As shown in Table VII-22, 38 products reflecting 60 percent of the market for aerosol 

Wasp or Hornet Insecticide products already comply with the proposed 10 percent by 

weight VOC limit. This indicates that further reductions can be achieved from this 

category and that the proposed VOC limit is both technologically and commercially 

feasible. 

Compliance with the proposed 10 percent by weight VOC limit is expected to be 

accomplished by reformulating products with up to 10 percent VOC solvent or VOC 

propellant along with VOC and LVP-VOC solvent mixtures, water, or non-VOC 

propellant. These technologies are currently available and widely accepted in both the 

household and institutional markets as shown by the 2006 Survey. In addition, the 2006 

Survey indicates that companies will be able to maintain their dielectric strength and 

knockdown capabilities using an LVP-VOC only solvent system. 

Proposed GWP Limit: 

No solvents or propellants with high GWP values were reported in the Wasp or Hornet 

Insecticide category surveyed in 2006. However, to ensure that use of compounds with 

higher GWP values does not begin as products reformulate to comply with the proposed 

10 percent by weight VOC limit, we are proposing a GWP limit of 150 for any chemical 

compound used in aerosol Wasp or Hornet Insecticide products, effective 

December 31, 2013. While this proposal would allow use of the non-VOC propellant, 

HFC-152a, we believe other reformulation options are more likely. The proposed limit 

would not apply to any chemicals present as contaminants, which in aggregate are 
Technical Support Document Chapter VII - 105 

0.1 percent by weight or less. This limit is proposed as a mitigation measure under 

CEQA (see Chapter IX, Environmental Impacts, section E). The proposed limit is 

contained in section 94509(n). 

REFERENCES 

1. AgrEvo Environmental Health. Aerosol Insecticides – A technical review. June 

23, 2010. (AgrEvo, 2010) 

2. Air Resources Board. Title 17, California Code of Regulations, Division 3, 

Chapter 1, Subchapter 8.5, Article 2, Consumer Products, Sections 94507-94517

(California Consumer Products Regulation. July 2009. (ARB, 2009d) 

3. Air Resources Board. 2008 Consumer & Commercial Products Survey Update 

for Dry Clean Only Spot Removers. January 14, 2009. (ARB, 2009e) 

4. Air Resources Board. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation. May 9, 2008. (ARB, 2008a) 

5. Air Resources Board. Airborne Toxic Control Measure for Emissions of 

Perchloroethylene from Dry Cleaning and Water-Repelling Operations. 

December 27, 2007. (ARB, 2007b) 

6. Air Resources Board. 2006 Consumer and Commercial Products Survey 

(Including Aerosol Coating Products). July 24, 2007. (ARB, 2007e) 

7. Air Resources Board. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation and the Aerosol Coatings 

Regulation. September 29, 2006. (ARB, 2006a) 

8. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

November 2004. (ARB, 2004a) 

9. Air Resources Board. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation: Midterm Measures II. 

 September 10, 1999. (ARB, 1999) 

10. Air Resources Board. Final Statement of Reasons for Rulemaking, Including

Summary of Comments and Agency Responses Public Hearing to Consider 

Adoption of Amendments to the California Consumer Products Regulation -

Midterm Measures I. July 24, 1997. (ARB, 1997a)

11. Air Resources Board. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation: Midterm Measures I. 

 June 6, 1997. (ARB, 1997b) 
Technical Support Document Chapter VII - 106 

12. Air Resources Board. Proposed Amendments to the Statewide Regulation to 

Reduce Volatile Organic Compound Emissions from Consumer Products –

Phase II – Staff Report. October, 1991. (ARB, 1991) 

13. Air Resources Board. Proposed Regulation to Reduce Volatile Organic 

Compound Emissions from Consumer Products – Staff Report. 

 August 1990. (ARB, 1990) 

14. California Department of Public Health. Health Benefits. Memorandum dated 

September 16, 2010, from Gilberto Chavez, M.D., M.P.H., State Epidemiologist, 

Deputy Director, Center for Infectious Diseases, to Richard Corey, Chief, 

Stationary Source Division, Air Resources Board. (CA DPH, 2010) 

15. ChemistryQuestion.com. The difference between anionic and nonionic 

surfactant, and its application to detergent. July 30, 2008. 

http://www.chemistryquestion.com/English/Questions/ChemistryInDailyLife/27c_n

onionic_surfactant.html. (CQ, 2008) 

16. Claire Manufacturing Company. Claire Technical Information: Jet Force Wasp 

and Hornet Killer. September 15, 2010. 

http://www.clairemfg.com/downloads/techsheets/ts-c005.pdf. 

 (Claire, 2010) 

17. Consumer Specialty Products Association. CSPA Product Technology Seminar 

for ARB Staff. June 29-30, 2010. (CSPA, 2010a) 

18. Consumer Specialty Products Association. Initial CSPA Comments on Draft Staff 

Proposal for 2010 Amendments to the California Consumer Products 

Regulation. May 28, 2010. (CSPA, 2010b) 

19. Institute for Research and Technical Assistance. Safer Alternatives for the Textile 

Cleaning Industry: Alternative Spotting Agents and Evaluation of Improvements 

in Carbon Dioxide and Wet Cleaning Technologies. November, 2009. 

 (IRTA, 2009) 

20. McLaughlin Gormley King Company. Data on Particle Size for Flying Bug 

Insecticides. July 15, 2010. (MGK, 2010) 

21. Procter & Gamble: Science in-the-box. Chemical Functional Definitions: 

Surfactants. August 13, 2010. 

http://www.scienceinthebox.com/en_UK/glossary/surfactants_en.html#five 

 (PG, 2010) 
Technical Support Document Chapter VII - 107 

22. San Francisco Estuary Institute. Occurrence of Alkylphenol Ethoxylate 

Surfactants in San Francisco Bay and Potential Impacts on Water Quality. 

Memorandum dated July 13, 2010, from Rainer Hoenicke, Ph.D., Executive 

Director, San Francisco Estuary Institute, to Darrin Polhemus, Deputy Director, 

Division of Water Quality, State Water Resources Control Board. (SFEI, 2010) 

23. Schafer, E. The Science of Dilution. Maintenance Supplies. 

September 23, 2008. 

http://www.maintenancesuppliesmag.com/publication/index.jsp?issueId=32 

(Schafer, 2008) 

24. Southern California Coastal Water Research Project. Effects on Water Quality of

Alkylphenol Ethoxylate Surfactants (APEOs). Memorandum dated July 15, 2010, 

from Keith Maruya, Principle Scientist, Southern California Coastal Water 

Research Project, to Darrin Polhemus, Deputy Director, Division of Water 

Quality, State Water Resources Control Board. (SCCWRP, 2010) 

25. State Coalition for Remediation of Dry Cleaners. Glossary of Drycleaning Terms. 

September 15, 2010. 

http://www.drycleancoalition.org/docdisplay.cfm?doc=dcglossary.htm 

 (SCRDC, 2010) 

26. State Water Resources Control Board. Water Quality Effects of Alkylphenol 

Ethoxylate Surfactants. Memorandum dated September 20, 2010, from Darrin 

Polhemus, Deputy Director, Division of Water Quality, State Water Resources 

Control Board, to Richard Corey, Chief, Stationary Source Division, Air 

Resources Board. (SWRCB, 2010a) 

27. State Water Resources Control Board. Effects on Water Quality of Alkylphenol 

Ethoxylate Surfactants. Memorandum dated July 19, 2010, from Valerie Connor, 

Ph.D., Deputy Director, Office of Information Management and Analysis, State 

Water Resources Control Board, to Darrin Polhemus, Deputy Director, Division of 

Water Quality, State Water Resources Control Board. (SWRCB, 2010b) 

28. United States Environmental Protection Agency. Pesticides: Regulating 

Pesticides – Inert Ingredients Permitted in Pesticide Products. 

 June 25, 2010. www.epa.gov/opprd001/inerts/lists.html. (U.S. EPA, 2010a) 

29. United States Environmental Protection Agency. Pesticides: Regulating 

Pesticides – Pyrethroids and Pyrethrins. March 24, 2010. 

http://www.epa.gov/oppsrrd1/reevaluation/pyrethroids-pyrethrins.html. 

 (U.S. EPA, 2010b) 

30. United States Environmental Protection Agency. Pesticides: Science and Policy

– Standard Operating Procedures – Product Properties. General Guidance to 
Technical Support Document Chapter VII - 108 

Reviewers of Product Properties Data, Labels, and Confidential Statements of 

Formula Submitted for Registration and Reregistration of Pesticide Chemicals 

(Conventional). January 8, 2003. (U.S. EPA, 2003b) 

31. United States Environmental Protection Agency, Design for the Environment. 

Garment and Textile Care Program. Frequently Asked Questions About 

Drycleaning. June, 1998. (U.S. EPA, 1998b) 

32. Willard, D.M., Barraza G., Zook, J.D. Waterless Hand Cleaner Containing Plant 

Derived Natural Essential Oil. United States Patent Number 6,884,763 B2. 

 April 26, 2005. (Willard et al., 2005) 
Technical Support Document Chapter VIII - 109 

Chapter VIII. Economic Impacts

This chapter provides our analysis of the estimated economic and fiscal impacts of the 

proposed amendments. The analysis focuses on costs to comply with the proposed 

volatile organic compound (VOC) limits. We expect the other proposals such as 

mitigation measures to prohibit use of certain toxic air contaminants, limit the use of 

greenhouse gases with high global warming potential values, and preclude use of 

alkylphenol surfactants to result in negligible or no costs. Proposed amendments to 

Test Method 310 will have no economic or fiscal impact. Businesses that manufacture 

products with VOC contents above the proposed VOC limits would incur costs to 

reformulate their products. Potential fiscal impacts would be costs incurred by State 

agencies to administer, enforce, or comply with the proposal. 

Economic impact analyses are imprecise, given the unpredictable behavior of 

companies in a highly competitive market such as consumer products. While staff has 

quantified the economic impacts to the extent feasible, some projections are necessarily 

qualitative, and based on general observations and facts known about the consumer 

products industry. This analysis, therefore, serves to provide a general picture of the 

economic impacts typical businesses might encounter. Individual companies may 

experience different impacts than projected. 

The summary of economic and fiscal impacts of the proposed VOC limits is presented 

in section A. The other sections provide the step-by-step details of how we determined 

the compliance costs and potential impacts. Section F contains information on 

alternative means of compliance. 

This economic impacts analysis was conducted in accordance with the current legal 

requirements under the Administrative Procedure Act (APA). This analysis uses similar 

methodologies and assumptions as were used in the 2009 consumer products 

rulemaking (ARB, 2009c).

A. Summary of Economic Impacts

Staff has estimated that the overall cost to comply with the proposed VOC limits is 

about $5 million per year for ten years (just under $50 million in total). This amount 

includes both recurring (e.g., raw materials) and nonrecurring (e.g., research and 

development) costs and is estimated based on assumptions specific to each category. 
Technical Support Document Chapter VIII - 110 

The cost represents the average of low and high cost estimates and is staff’s prediction 

of the costs businesses would most likely incur. 

Another measure of the economic impacts of the proposal is to determine the “dollars to 

be spent per pound of VOC reduced,” or cost-effectiveness (CE). The CE of the 

proposed amendments has been calculated to be about $0.98 per pound of VOC 

reduced. This is based on expected emission reductions of about 6.9 tons per day. 

The CE of other recent consumer products rulemakings has ranged from about $0.30 to 

about $6.25. Based on this range, staff believes the proposed amendments are cost 

effective. 

The impacts of the proposed amendments on manufacturers are estimated by 

determining the “return on owner’s equity” (ROE). In the ROE analysis we compare a 

company’s percentage reduction in profitability before and after incurring the costs 

associated with the proposed amendments. The analysis found that the overall 

reduction in profitability ranges from about 1 percent to about 3 percent. The overall 

average decline in ROE is about 1.6 percent. To the extent that the projected costs are 

passed on to consumers, the impact on business profitability is likely to be much less 

than estimated in our projection. 

Because we expect some businesses will pass on at least a portion of their compliance 

costs to the consumer, we estimated the increased cost the consumer may experience. 

If all assumed compliance costs are passed on to the consumer, without consideration 

of typical retail mark-up, we estimate the cost per unit increase would range from 

negligible cost (net savings or no cost) for a nonaerosol General Purpose Cleaner 

product to about $0.44 for a Heavy-duty Hand Cleaner or Soap product. When 

considering normal retail mark-up of 100 percent, increased cost to the consumer to 

purchase a Heavy-duty Hand Cleaner or Soap product would increase by about 

$0.90 per gallon. 

Based on our ROE calculations, we believe that overall, most affected businesses will 

be able to absorb the costs, or will pass through some of the costs to the consumer, 

such that there will be no significant adverse impacts on their profitability. Therefore, 

we do not expect a noticeable change in employment; business creation, elimination or 

expansion; or business competitiveness in California. However, the proposed 

amendments may impose economic hardship on some businesses with very little or no 

margin of profitability. 

We determined that there would be no significant adverse fiscal impacts to any local or 

State agencies. While not significant, ARB will have costs in the future to enforce the 

new limits proposed here. 

Staff believes that the regulation cost and CE determination methodologies are 

conservative. For example, the average cost scenario of low and high determines the 

overall cost and CE of the regulation. The low cost scenario assumes that companies 

would choose the lowest cost reformulation pathway, making minor adjustments to a 
Technical Support Document Chapter VIII - 111 

product’s formulation, or simply ceasing sale of some noncomplying products. We 

believe that most manufacturers would choose the lowest cost reformulation option. For 

the high cost scenario, it is assumed that there is significant research and development, 

and new equipment is needed to reformulate the product. We believe that few 

manufacturers would need to take the high cost reformulation approach. 

Details of our cost analysis are in the following sections. Additional information as to 

how recurring and nonrecurring costs were estimated is contained in Appendices D 

and E. 

B. Costs of Compliance 

To determine the total cost to comply with the proposal, recurring and nonrecurring 

costs are estimated. These estimates are representative of the costs expended to 

reformulate and bring a product to market. Recurring costs for this analysis are those 

associated with the cost of the raw materials. Nonrecurring costs are assumed to be 

one time costs and are those associated with research, development, and plant 

changes that may be necessary to develop a reformulated complying product. Our 

analysis further assumes that nonrecurring costs will be amortized over a project 

horizon of ten years. Summing the recurring and amortized nonrecurring costs 

represents the total cost to reformulate a product. We then use the total cost to 

estimate the potential cost per unit increase to the consumer, the CE of the proposed 

amendments, and the ROE. 

There are many variables in producing a product for market, and assumptions about 

those variables will greatly affect the outcome of any cost analysis. For each 

assumption, staff applied a test of “reasonableness” to determine if this was a likely 

approach to take, or if the event had a high probability of occurring. The following 

sections describe our process for arriving at the costs to comply with the proposed 

amendments. 

1. Recurring Costs 

As part of the economic impact analysis, we evaluated the expected cost impacts from 

complying with the proposed VOC limits on raw material costs. The change in the cost 

of raw material costs are expected to be ongoing, i.e., they are recurring costs. 

 a. Methodology

Using the data from the 2006 Survey and the 2008 Survey Update staff determined the 

formulations which most closely reflect the “typical” formulations for compliant and 

noncompliant products in each category. For each category staff estimated a “low cost” 

and “high cost” by varying costs for ingredients. Information on how raw material costs 

were estimated, as well as formulations evaluated (with individual weight fractions and 

unit prices per pound), are shown in Appendix D. While these formulations may not 

reflect the exact composition of existing noncompliant products and compliant products 
Technical Support Document Chapter VIII - 112 

that will be marketed, we believe they are reasonably representative for the purposes of 

this analysis. 

Except for ingredient costs, we assumed changes in packaging, delivery systems, 

labeling, distribution and other recurring costs would be negligible relative to baseline 

levels of these costs (ARB, 1997b). We believe this assumption is valid because the 

proposed limits should not require significant packaging or delivery system 

modifications. We also believe distribution costs would be the same because we do not 

expect manufacturers to sell and distribute “California only products.” The most likely 

pathway for reformulation was assumed for noncompliant products. Despite this 

assumption, alternative formulations may allow lower-cost compliant products than 

shown in our analysis. 

b. Results

The estimated cost of typical noncompliant and compliant formulations for each 

category is displayed in Table VIII-1a. The values in columns A and B are taken from 

Appendix D. The difference between high and low cost of noncompliant and compliant 

formulations yields the change in ingredient costs. As shown in Table VIII-1a, Columns 

C1 and C2, the anticipated raw materials cost change ranges from no cost (net savings 

or no cost) for a 23 ounce General Purpose Degreaser (nonaerosol) product to about 

$0.64 increase per unit for a 133 ounce Heavy-duty Hand Cleaner or Soap. In 

instances when the cost for raw materials in the predicted reformulated product are 

comparable or slightly cheaper to those currently used, rather than assigning a negative 

cost, we assume there will be no change in the cost of raw materials. 

Using the change in the cost per unit from Table VIII-1a, the total recurring costs per 

category are calculated as shown in Table VIII-1b. To arrive at the total cost per 

category, estimated noncompliant unit sales (Column D) are multiplied by the recurring 

costs per unit taken from Table VIII-1a, Columns C1 and C2. As shown in Table VIII-1b, 

Column E3 the average total recurring cost per category ranges from no cost for several 

categories to about $346,900 for the Heavy-duty Hand Cleaner or Soap products 

reformulated to comply with the 1 percent VOC limit. 

 2. Nonrecurring Costs 

In this portion of the analysis, we evaluated the impacts of nonrecurring costs likely to 

be expended to comply with the proposed limits. These are assumed to be costs 

incurred once to conduct the necessary research and development to produce a 

complying product. Technical literature and industry trade journals provide little 

information to estimate nonrecurring costs directly. This is not surprising because the 
Technical Support Document Chapter VIII - 113 

Table VIII-1a 

Estimated Change in Formula Cost per Unit* 

Formula Cost per Unit 

Noncomplying 

 Low High 

Complying 

 Low High 

Cost Increase to 

Comply per Unit 

Low High 

Category A1 A2 B1 B2

C1= 

B1 – A1

C2 = 

B2 –A2

Furniture Maintenance 

Product (aerosol) $0.31 $0.57 $0.35 $0.60 $0.04+ $0.04+

General Purpose 

Cleaner (nonaerosol) $0.19 $0.25 $0.13 $0.17 $0.00 $0.00 

General Purpose 

Degreaser (nonaerosol) $0.34 $0.50 $0.22 $0.39 $0.00 $0.00 

Glass Cleaner 

(nonaerosol) $0.07 $0.10 $0.06 $0.08 $0.00 $0.00 

Heavy-duty Hand 

Cleaner or Soap $4.76 $8.30 $4.99 $8.93 $0.23 $0.64 

Insecticide – Flying Bug 

(aerosol) $0.44 $0.71 $0.36 $0.57 $0.00 $0.00 

Insecticide – Wasp or 

Hornet (aerosol) $0.69 $0.86 $0.80 $0.93 $0.11 $0.07 

Lubricant – Special 

Purpose (aerosol) $0.52 $0.72 $0.51 $0.71 $0.00 $0.00 

Lubricant – Special 

Purpose (nonaerosol) $0.63 $0.82 $0.65 $0.85 $0.02 $0.03 

Oven or Grill Cleaner 

(aerosol) $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 

Oven or Grill Cleaner 

(nonaerosol) $3.65 $4.26 $2.07 $3.67 $0.00 $0.00 

Spot Remover – Dry 

Clean Only (aerosol) $0.93 $1.36 $0.79 $1.14 $0.00 $0.00 

Spot Remover – Dry 

Clean Only 

(nonaerosol) 

$1.44 $1.81 $1.35 $1.78 $0.00 $0.00 

Metal Polish or 

Cleanser (aerosol) $0.96 $1.14 $0.32 $0.40 $0.00 $0.00 

Metal Polish or 

Cleanser (nonaerosol) $1.07 $1.25 $0.41 $0.46 $0.00 $0.00 

 * Raw material costs are assumed to be $0.00 when staff estimates that materials used to 

 reformulate are comparably priced to current materials or are less expensive than currently 

 used. 

 + Numbers have been rounded in tables, however unrounded numbers are used for calculations. 

consumer products industry is competitive, and production cost data specific to a 

company are closely guarded trade secrets. Stakeholders have generally concurred 

that our assumptions for nonrecurring costs are reasonable. Appendix E displays the 

various phases of product development and the costs that are assigned to each phase. 
Technical Support Document Chapter VIII - 114 

Table VIII-1b 

Total Estimated Recurring Cost 

Annual 

California 

Noncomplying 

Unit Sales* 

Total Annual Recurring Cost per 

Category+

 LOW HIGH AVERAGE 

Category 

D E1 = 

D X C1** 

E2 = 

D X C2** 

E3 = 

(E1+E2)/2 

Furniture Maintenance 

Product (aerosol) 5,205,245 $218,236 $185,053 $201,645 

General Purpose 

Cleaner (nonaerosol) 47,023,377 $0.00 $0.00 $0.00 

General Purpose 

Degreaser (nonaerosol) 2,114,007 $0.00 $0.00 $0.00 

Glass Cleaner 

(nonaerosol) 23,775,680 $0.00 $0.00 $0.00 

Heavy-duty Hand 

Cleaner or Soap 

(nonaerosol) 

802,431 $181,710 $512,122 $346,916 

Insecticide – Flying Bug 

(aerosol) 1,022,141 $0.00 $0.00 $0.00 

Insecticide – Wasp or 

Hornet (aerosol) 1,024,272 $110,237 $67,218 $88,728 

Lubricant – Special 

Purpose (aerosol) 314,820 $0.00 $0.00 $0.00 

Lubricant – Special 

Purpose (nonaerosol) 310,193 $4,715 $10,258 $7,487 

Oven or Grill Cleaner 

(aerosol) 68,952 $0.00 $0.00 $0.00 

Oven or Grill Cleaner 

(nonaerosol) 12,406 $0.00 $0.00 $0.00 

Spot Remover – Dry 

Clean Only (aerosol) *** $0.00 $0.00 $0.00 

Spot Remover – Dry 

Clean Only 

(nonaerosol) 

159,754 $0.00 $0.00 $0.00 

Metal Polish or 

Cleanser (aerosol) 443,930 $0.00 $0.00 $0.00 

Metal Polish or 

Cleanser (nonaerosol) 422,410 $0.00 $0.00 $0.00 

* Assumes “typical” unit size as shown in Appendix D. 

** C1 and C2 are from Table VIII-1a 

 + Numbers have been rounded in tables, however unrounded numbers are used for 

 calculations. 

 *** Data are confidential. 

 
Technical Support Document Chapter VIII - 115 

 a. Methodology

To estimate nonrecurring costs, we used two approaches for each product category, 

one for low cost, and one for high cost, with a different set of assumptions for each 

approach. The categories proposed for regulation are considered “household care” or 

“pesticide and disinfectant” products. 

Appendix E displays the various high and low nonrecurring costs for each of these 

sectors. For each category only new or additional costs were considered. Costs were 

not considered that would have been expected in the normal course of business if the 

regulation had not been in effect. 

 b. Results

Table VIII-2, Columns A1 and A2, display the results of our assessment of the 

nonrecurring costs to be incurred for each category. These costs are taken from 

Appendix E. Estimated nonrecurring costs for the low cost scenario range from about 

$300 to $11,600 per category. Note also that nonrecurring costs for the high cost 

scenario range from about $4,900 to $160,250 per category. 

 c. Amortizing Nonrecurring Costs

The next part of our analysis assumes that nonrecurring costs will not be incurred in a 

single year, but would instead be amortized over ten years. The nonrecurring costs 

shown in Columns A1 and A2 are amortized using the Capital Recovery Method. This is 

a standard methodology and it is recommended under guidelines issued by the 

California Environmental Protection Agency (Cal/EPA). 

The equation below shows that the estimated total nonrecurring costs per product is 

multiplied by the Capital Recovery Factor (CRF) to convert these costs into equal 

annual payments over a project horizon (i.e., the projected useful life of the investment) 

at a discount rate. 

Annualized nonrecurring costs = (Nonrecurring Costs) X [i(1 + i)n /((1 + i)n-1)] 

 Where: 

 i(1 + i)n /((1 + i)n-1) = Capital Recovery Factor (CRF) 

 i = discount interest rate over project horizon, % 

 n = number of years in project horizon 

 Nonrecurring Costs = total nonrecurring cost per product 

We assumed a project horizon of ten years, a commonly cited period for an 

investment’s useful lifetime in the chemical processing industry. We also assumed a 
Technical Support Document Chapter VIII - 116 

Table VIII-2 

Estimated Nonrecurring per Product Costs to Comply with the Proposed Limits

Cost Per Product 

 Low High 

Amortized Cost Per Product 

 Low High 

Category A1 A2

B1 = 

A1 X CRF* 

B2 = 

A2 X CRF* 

Furniture Maintenance 

Product (aerosol) $11,638 $43,570 $1,894 $7,091 

General Purpose Cleaner 

(nonaerosol) $7,311 $38,795 $1,190 $6,314 

General Purpose Degreaser 

(nonaerosol) $7,311 $28,350 $1,190 $4,614 

Glass Cleaner (nonaerosol) $1,641 $9,400 $267 $1,530 

Heavy-duty Hand Cleaner 

or Soap (nonaerosol) $448 $5,968 $73 $971 

Insecticide – Flying Bug 

(aerosol) $1,641 $56,402 $267 $9,179 

Insecticide – Wasp or 

Hornet (aerosol) $298 $140,855 $48 $22,924 

Lubricant – Special Purpose 

(aerosol) $597 $26,858 $97 $4,371 

Lubricant – Special Purpose 

(nonaerosol) $6,118 $27,902 $996 $4,541 

Oven or Grill Cleaner 

(aerosol) $5,670 $19,696 $923 $3,205 

Oven or Grill Cleaner 

(nonaerosol) $5,670 $19,696 $923 $3,205 

Spot Remover – Dry Clean 

Only (aerosol) $3,432 $160,253 $559 $26,080 

Spot Remover – Dry Clean 

Only (nonaerosol) $1,940 $119,369 $316 $19,427 

Metal Polish or Cleanser 

(aerosol) $746 $4,924 $121 $801 

Metal Polish or Cleanser 

(nonaerosol) $746 $4,924 $121 $801 

 *CRF = Capital Recovery Factor of 0.16275 

 

fixed interest rate of 10 percent throughout the project horizon. These assumptions are 

conservative and constitute standard practice in analyses of consumer products 

regulations, including previous consumer product rulemakings. Based on these 

assumptions, the Capital Recovery Factor (CRF), as shown below, is 0.16275. 

 

 CRF = 0.1(1+0.1)10/((1+0.1)10-1) 

 = 0.1(2.59)/1.59 

 = 0.259/1.59 

 = 0.163 (rounded) 
Technical Support Document Chapter VIII - 117 

Using the low cost estimate for Furniture Maintenance Product (aerosol) from 

Table VIII-2, Column A1, then the amortized cost is: 

 Amortized Cost: $11,638 X 0.16275 = $1,894 

For the low cost scenario, as shown in Column B1, of Table VIII-2, we project perproduct annualized nonrecurring costs to be about $50 to $1,900 for each of ten years. 

For the high cost scenario (Column B2), we project per-product annualized nonrecurring 

costs to range from about $800 to $26,000 for each of ten years. 

Next, nonrecurring costs for all noncomplying products per category are calculated by 

using the low and high amortized costs from Table VIII-2, Columns B1 and B2. To arrive 

at the range of total nonrecurring cost per category, two different scenarios are 

calculated. In the low cost scenario, we assume that manufacturers will conduct 

research and other product development once for a given product category, and use 

these efforts as a basis to reformulate all their other noncomplying products in the same 

category. As shown in Table VIII-3, the low cost incurred by all businesses is the 

product of the low product cost (Column C) and number of companies (Column B) that 

have noncomplying products within the given category. 

In the total nonrecurring high cost scenario, we assume that reformulation costs would 

be incurred per product. This means that companies that have multiple noncomplying 

products in a given category would conduct separate research and development efforts 

for each product in their respective product lines. Thus in this case, the high amortized 

cost (Column D) is multiplied by the number of noncomplying products (Column A). 

As shown in Table VIII-3, total category annualized nonrecurring costs for the low cost 

scenario range from about $560 for a Spot Remover (Dry Clean Only) (aerosol) product 

to $161,800 for a General Purpose Cleaner (nonaerosol) product. For the high cost 

scenario, costs range from $9,600 for an Oven or Grill Cleaner (aerosol) product to 

$3,775,600 for a General Purpose Cleaner (nonaerosol) product. The high cost 

scenario for a General Purpose Cleaner (nonaerosol) product is overestimated. This is 

because to calculate this cost we assumed that all General Purpose Cleaner 

(nonaerosol) products would incur the costs for the registration required by the Federal 

Insecticide, Fungicide, and Rodenticide Act (FIFRA). In reality only about 5 percent of 

products are currently registered as FIFRA products. Therefore, this cost estimate is 

conservative. Also as shown in Table VIII-3, the total nonrecurring cost to industry is 

projected to range from about $389,200 to just over $8,217,300 dollars per year for ten 

years. 

3. Total Costs 

For each category, the total cost of reformulation is estimated by summing recurring 

costs (see Table VIII-1b, Columns E1 and E2) with nonrecurring amortized costs (see 

Table VIII-3, Columns E1 and E2). Table VIII-4 displays the total low and high cost to 
Technical Support Document Chapter VIII - 118 

Table VIII-3 

Estimated Total Nonrecurring Cost per Category

# Noncomplying 

Products* 

# 

Companies 

Low 

Cost/ 

Product 

High 

Cost/ 

Product 

Total Nonrecurring 

 Cost per Category 

 Low High 

Category A B C D E1 = 

B X C 

E2 = 

D X A 

Furniture 

Maintenance 

Product (aerosol) 

56 30 $1,894 $7,091 $56,821 $397,086 

General Purpose 

Cleaner 

(nonaerosol) 

598 136 $1,190 $6,314 $161,817 $3,775,597

General Purpose 

Degreaser 

(nonaerosol) 

257 82 $1,190 $4,614 $97,566 $1,185,755

Glass Cleaner 

(nonaerosol) 148 80 $267 $1,530 $21,365 $226,411 

Heavy-duty Hand 

Cleaner or Soap 

(nonaerosol) 

161 51 $73 $971 $3,718 $156,374 

Insecticide – Flying 

Bug (aerosol) 37 23 $267 $9,179 $6,142 $339,629 

Insecticide – Wasp 

or Hornet (aerosol) 20 14 $48 $22,924 $679 $458,470 

Lubricant – Special 

Purpose (aerosol) 118 43 $97 $4,371 $4,178 $515,780 

Lubricant – Special 

Purpose 

(nonaerosol) 

66 18 $996 $4,541 $17,922 $299,701 

Oven or Grill 

Cleaner (aerosol) 3 3 $923 $3,205 $2,768 $9,616 

Oven or Grill 

Cleaner 

(nonaerosol) 

9 5 $923 $3,205 $4,614 $28,849 

Spot Remover – 

Dry Clean Only 

(aerosol) 

1 1 $559 $26,080 $559 $26,080 

Spot Remover – 

Dry Clean Only 

(nonaerosol) 

36 5 $316 $19,427 $1,579 $699,363 

Metal Polish or 

Cleanser (aerosol) 59 37 $121 $801 $4,492 $47,280 

Metal Polish or 

Cleanser 

(nonaerosol) 

64 41 $121 $801 $4,978 $51,287 

Total: 1,633 $389,198 $8,217,278

* Adjusted for market covered in survey. Assume 90% market coverage for all categories. 
Technical Support Document Chapter VIII - 119 

reformulate all noncomplying products for each category. As shown in Table VIII-4, 

Column C1, we estimate the low per year industry compliance costs to range from a low 

of about $560 for Spot Remover (Dry Clean Only) (aerosol) products, to a high of about 

$275,000 for a Furniture Maintenance Product (aerosol) product. We estimate the high 

per year industry compliance costs to range from a low of about $9,600 for Oven or Grill 

Cleaner (aerosol) products, to a high of about $3,775,600 for General Purpose Cleaner 

(nonaerosol) products. Again, this cost for General Purpose Cleaner (nonaerosol) 

products is conservative based on the assumption that all products would incur the 

costs of FIFRA registration. Table VIII-4 (Column C3) also shows the average cost 

estimates to range from about $6,200 for Oven or Grill Cleaner (aerosol) products to 

$1,968,700 for General Purpose Cleaner (nonaerosol) products (Column C2). As 

shown in Column C3, the overall average cost to reformulate all noncomplying products 

for all categories is just under $5 million. 

4. Cost per Unit 

We also evaluated the potential increased cost the consumer would pay if all costs of 

compliance were passed onto the consumer (not including retail mark-up). For this 

estimate, we assumed that all recurring and nonrecurring costs are assessed only to the 

number of noncomplying units in each category. Tables VIII-5a and VIII-5b display the 

result of this analysis. 

For this rulemaking, as with others, we assumed products reformulated to meet the 

proposed limits will be marketed throughout the United States by national marketers. 

From our experience, we know that businesses generally formulate and distribute to the 

entire nation, products complying with California regulations, rather than incurring the 

additional cost of setting up a California specific product distribution system. This 

assumption is valid especially considering the number of jurisdictions that have, and are 

continuing to adopt California standards. 

Therefore, we assume that the costs of compliance will not be assessed only to 

products sold in California, but will be spread over products sold across the country. To 

do this, our analysis used the California-apportioned (by population) high and low 

nonrecurring costs (Table VIII-3). Using this alternative approach, we discounted the 

nonrecurring cost per unit by the California-apportionment factor (i.e., the current ratio of 

California to U.S. population, or 12.0 percent (U.S. Census, 2010)). To illustrate, using 

the total nonrecurring high cost for Special Purpose Lubricant (nonaerosol) products of 

$299,701 the nonrecurring portion of cost that would be passed onto California 

consumers is 12 percent of this amount, or about $36,000. The California portion of low 

and high nonrecurring costs (Table VIII-3, Columns E1 and E2) are each divided by the 

number of noncomplying units sold in California per year (see column A of Table VIII5b). The resulting nonrecurring high and low cost per unit is then added to the recurring 

high and low cost per unit (taken from Table VIII-1a, Columns C1 and C2) to arrive at the 

total increase in cost per unit to the consumer. 
Technical Support Document Chapter VIII - 120 

Table VIII-4 

Estimated Total Costs to Comply with the Proposed VOC Limits

Nonrecurring Costs Recurring Costs*

Low High Low High 

A1 A2 B1 B2

Furniture Maintenance Product (aerosol) $56,821 $397,086 $218,236 $185,053 

General Purpose Cleaner (nonaerosol) $161,817 $3,775,597 $0.00 $0.00 

General Purpose Degreaser (nonaerosol) $97,566 $1,185,755 $0.00 $0.00 

Glass Cleaner (nonaerosol) $21,365 $226,411 $0.00 $0.00 

Heavy-duty Hand Cleaner or Soap $3,718 $156,374 $181,710 $512,122 

Insecticide – Flying Bug (aerosol) $6,142 $339,629 $0.00 $0.00 

Insecticide – Wasp or Hornet (aerosol) $679 $458,470 $110,237 $67,218 

Lubricant – Special Purpose (aerosol) $4,178 $515,780 $0.00 $0.00 

Lubricant – Special Purpose (nonaerosol) $17,922 $299,701 $4,715 $10,258 

Oven or Grill Cleaner (aerosol) $2,768 $9,616 $0.00 $0.00 

Oven or Grill Cleaner (nonaerosol) $4,614 $28,849 $0.00 $0.00 

Spot Remover – Dry Clean Only 

(aerosol) $559 $26,080 $0.00 $0.00 

Spot Remover – Dry Clean Only 

(nonaerosol) $1,579 $699,363 $0.00 $0.00 

Metal Polish or Cleanser (aerosol) $4,492 $47,280 $0.00 $0.00 

Metal Polish or Cleanser (nonaerosol) $4,978 $51,287 $0.00 $0.00 

Nonrecurring and Recurring Costs+

Low High Average 

C1= C2= C3= 

A1+ B1 A2+ B2 (C1+ C2)/2 

Furniture Maintenance Product (aerosol) $275,057 $582,139 $428,598 

General Purpose Cleaner (nonaerosol) $161,817 $3,775,597 $1,968,707 

General Purpose Degreaser (nonaerosol) $97,566 $1,185,755 $641,660 

Glass Cleaner (nonaerosol) $21,365 $226,411 $123,888 

Heavy-duty Hand Cleaner or Soap 

(nonaerosol) $185,428 $668,496 $426,962 

Insecticide – Flying Bug (aerosol) $6,142 $339,629 $172,886 

Insecticide – Wasp or Hornet (aerosol) $110,916 $525,688 $318,302 

Lubricant – Special Purpose (aerosol) $4,178 $515,780 $259,979 

Lubricant – Special Purpose (nonaerosol) $22,637 $309,959 $166,298 

Oven or Grill Cleaner (aerosol) $2,768 $9,616 $6,192 

Oven or Grill Cleaner (nonaerosol) $4,614 $28,849 $16,731 

Spot Remover – Dry Clean Only 

(aerosol) $559 $26,080 $13,319 

Spot Remover – Dry Clean Only 

(nonaerosol) $1,579 $699,363 $350,471 

Metal Polish or Cleanser (aerosol) $4,492 $47,280 $25,886 

Metal Polish or Cleanser (nonaerosol) $4,978 $51,287 $28,132 

TOTAL: $904,097 $8,991,929 $4,948,013 

 * A cost of $0 may indicate a per unit cost of less than one-half of one cent. 

 

+

 Numbers have been rounded in tables, however unrounded numbers are used for 

 calculations. 
Technical Support Document Chapter VIII - 121 

Table VIII-5a 

Estimated Per-Unit Cost Increases from Annualized Nonrecurring and Annual 

Recurring Costs* 

 Annual 

California 

Noncomplying 

Unit Sales 

Annualized 

Nonrecurring 

Low 

Cost/Unit**+

Annualized 

Nonrecurring 

High 

Cost/Unit 

Annual 

Recurring 

Low 

Cost/Unitz

Annual 

Recurring 

High 

Cost/Unitz

Category A B1 B2 C1 C2

Furniture 

Maintenance Product 

(aerosol) 

5,205,245 $0.00 $0.01 $0.04 $0.04

General Purpose 

Cleaner (nonaerosol) 47,023,377 $0.00 $0.01 $0.00 $0.00

General Purpose 

Degreaser 

(nonaerosol) 

2,114,007 $0.01 $0.07 $0.00 $0.00

Glass Cleaner 

(nonaerosol) 23,775,680 $0.00 $0.00 $0.00 $0.00

Heavy-duty Hand 

Cleaner or Soap 

(nonaerosol) 

802,431 $0.00 $0.02 $0.23 $0.64

Insecticide – Flying 

Bug (aerosol) 1,022,141 $0.00 $0.04 $0.00 $0.00

Insecticide – Wasp or 

Hornet (aerosol) 1,024,272 $0.00 $0.05 $0.11 $0.07

Lubricant – Special 

Purpose (aerosol) 314,820 $0.00 $0.20 $0.00 $0.00

Lubricant – Special 

Purpose (nonaerosol) 310,193 $0.01 $0.12 $0.02 $0.03

Oven or Grill Cleaner 

(aerosol) 68,952 $0.00 $0.02 $0.00 $0.00

Oven or Grill Cleaner 

(nonaerosol) 12,406 $0.04 $0.28 $0.00 $0.00

Spot Remover – Dry 

Clean Only (aerosol) 175,200 $0.00 $0.02 $0.00 $0.00

Spot Remover – Dry 

Clean Only 

(nonaerosol) 

159,754 $0.00 $0.53 $0.00 $0.00

Metal Polish or 

Cleanser (aerosol) 443,930 $0.00 $0.01 $0.00 $0.00

Metal Polish or 

Cleanser (nonaerosol) 422,410 $0.00 $0.01 $0.00 $0.00

* Numbers have been rounded in tables, however unrounded numbers are used for calculations. 

+ A cost of $0 may indicate a per unit cost of less than one-half of one cent. 

** Costs in Columns B1 and B2 arrived at by apportioning nonrecurring total costs from 

 Table VIII-3, Columns E1 and E2, by the percentage of California population (12%). 

z Costs are from Table VIII-1a, Columns C1 and C2. 
Technical Support Document Chapter VIII - 122 

Table VIII-5b 

Sum of Estimated Per-Unit Cost Increases from Both Annualized Nonrecurring 

and Annual Recurring Costs 

Total 

Increase 

Low/Unit*+

Total 

Increase 

High/Unit 

Total 

Increase 

Mid/Unit 

Category D1 D2 D3

Furniture Maintenance Product (aerosol) $0.04 $0.04 $0.04 

General Purpose Cleaner (nonaerosol) $0.00 $0.01 $0.01 

General Purpose Degreaser (nonaerosol) $0.01 $0.07 $0.04 

Glass Cleaner (nonaerosol) $0.00 $0.00 $0.00 

Heavy-duty Hand Cleaner or Soap 

(nonaerosol) $0.23 $0.66 $0.44 

Insecticide – Flying Bug (aerosol) $0.00 $0.04 $0.02 

Insecticide – Wasp or Hornet (aerosol) $0.11 $0.12 $0.11 

Lubricant – Special Purpose (aerosol) $0.00 $0.20 $0.10 

Lubricant – Special Purpose (nonaerosol) $0.02 $0.15 $0.09 

Oven or Grill Cleaner (aerosol) $0.00 $0.02 $0.01 

Oven or Grill Cleaner (nonaerosol) $0.04 $0.28 $0.16 

Spot Remover – Dry Clean Only (aerosol) $0.00 $0.02 $0.01 

Spot Remover – Dry Clean Only 

(nonaerosol) $0.00 $0.53 $0.26 

Metal Polish or Cleanser (aerosol) $0.00 $0.01 $0.01 

Metal Polish or Cleanser (nonaerosol) $0.00 $0.01 $0.01 

* A cost of $0 may indicate a per unit cost of less than one-half of one cent. 

+

 Numbers have been rounded in tables, however unrounded numbers are used for calculations. 

For most products the total cost of reformulating products is estimated to be quite 

minimal. The recurring raw materials costs to reformulate a number of products to meet 

the proposed VOC limits are projected to be zero. This is because the costs of 

ingredients of a complying product are actually less than the cost of ingredients of a 

noncomplying product. For the purposes of our cost calculations, in this case, as was 

done in economic analyses for previous rulemakings, we assume that the ingredient 

costs are zero. As for the nonrecurring costs (research and development), while these 

costs are significant, once the costs are spread over the number of units sold, the 

resulting overall cost per unit is negligible. 

As shown in Table VIII-5b, we estimate the average cost per unit increase to the 

California consumer to range from no cost increase to about $0.44. The worst case 

scenario cost increase would be about $0.66 for Heavy-duty Hand Cleaner or Soap 

products. This cost does not reflect typical retail mark-up. Because of unpredictable 

factors such as the highly competitive nature of the consumer products market, it is not 

possible to accurately predict the final retail price of products that will comply with the 

proposed limits when they become effective. To the extent the cost impacts are passed 

on to consumers, the final retail prices may be lower or higher than suggested by this 

analysis. 
Technical Support Document Chapter VIII - 123 

5. Cost-effectiveness (CE) 

Using the total costs displayed in Table VIII-4, we evaluated the anticipated CE of the 

proposed new limits. Such an evaluation allows us to compare the efficiency of the 

proposed limits in reducing a pound of VOC relative to other existing regulatory 

programs. 

The CE of a reduction strategy is generally defined as the ratio of total dollars to be 

spent to comply with the strategy (as an annual cost) to the mass reduction of the 

pollutant(s) to be achieved by complying with that strategy (in annual pounds). The CE 

is calculated as shown by the following general equation: 

 Cost-effectiveness = Total Annual Cost to Comply

 Annual Mass Reduction in VOC 

We estimate that, when fully effective, the proposed VOC limits will result in an emission 

reduction of about 6.9 tons per day, or 5,037,000 pounds per year. In this chapter, we 

have calculated that the average total annual cost to comply with the proposed VOC 

limits is $4,948,013. 

The CE of the proposed amendments related to complying with the VOC limits is about 

$0.98 per pound of VOC reduced, as shown by the following equation: 

 $4,948,013 = $0.98 per pound 

 5,037,000 

Table VIII-6 shows a comparison of the CE for the proposed limits relative to other 

recent ARB consumer product regulations and control measures. 

Table VIII-6 

Comparison of Cost-Effectiveness for ARB Consumer Product 

Regulations/Measures

Regulation/Control Measure 

Cost-Effectiveness 

(Dollars per Pound VOC Reduced) 

2010 Amendments $0.98 

2009 Amendments (ARB, 2009c) $0.29 

2008 Amendments (ARB, 2008a) $6.23 

2006 Amendments (ARB, 2006a) $2.35 

As shown in Table VIII-6, the CE compares favorably with other recent rulemakings. 
Technical Support Document Chapter VIII - 124 

C. Return on Owners’ Equity 

Typical California businesses are affected by the proposed new limits to the extent that 

the implementation of these requirements would change their profitability. To estimate 

reduction in profitability, this portion of the economic impacts analysis compares the 

Return on Owners’ Equity (ROE) for affected businesses before and after inclusion of 

the cost to comply with the proposed requirements. The data used in this analysis are 

obtained from Dun and Bradstreet Industry Norms and Key Business Ratio (D&B, 2008; 

D&B, 2009), the ARB’s 2006 Consumer and Commercial Products Survey (ARB, 

2007e), the Survey Update for Dry Clean Only Spot Remover products (ARB, 2009e), 

and the CE analysis described previously in section B.

1. Affected Businesses 

Any business which manufactures or markets consumer products subject to the 

proposed new limits and requirements can be directly affected by this regulation. Also 

potentially affected are businesses which supply raw materials or equipment to 

manufacturers or marketers, and those that distribute or sell consumer products in 

California. The focus of this analysis, however, will be on manufacturers, marketers, 

and distributors that are most affected by the proposed measures. 

The consumer products subject to the proposed measures are manufactured, marketed, 

or distributed by a large number of companies worldwide. According to our Surveys, 

there are about 244 companies that market the affected products in California. Many of 

these companies manufacture, market, and distribute a broad range of solvent, 

adhesive, household, and personal care products. All together, there are about 1,633 

noncomplying products (based on reported figures). Of the companies manufacturing 

these products, 29 small-sized firms are located in California. 

These 244 companies can be described by the North American Industry Classification 

System codes (NAICS): 325611, Soap and Other Detergent Manufacturing; 325612, 

Polish and Other Sanitation Goods manufacturing; 325320, Pesticides and Agricultural 

Chemicals; and 324191, Lubricant manufacturing. 

2. Analysis Approach 

This analysis covers 4 industries with at least 244 affected businesses. The approach 

used in evaluating the potential economic impact of the proposed measures on these 

businesses is as follows: 

 

(1) A typical business from each product category was selected from the 

respondents to the surveys. 

(2) A range of compliance costs were estimated for each affected product 

category. The average cost (see Table VIII-4) for each category was used 

in this analysis. 
Technical Support Document Chapter VIII - 125 

(3) Compliance cost to a typical business was then estimated based on a 

weighted average of all product category costs in the affected industry. 

(4) Estimated cost was adjusted for federal and State taxes. 

(5) The ROE was calculated for each of these businesses by dividing the net 

profit by the net worth. The adjusted cost was then subtracted from net 

profit data. The results were used to calculate an adjusted ROE. 

(6) The adjusted ROE was then compared with the ROE before the 

subtraction of the cost to determine the potential impact on the profitability 

of the business. 

An ROE reduction of more than 10 percent in profitability assuming that all costs are 

absorbed by the affected company and not passed on to the consumer, is considered to 

indicate a potential for significant adverse economic impacts. This value has been used 

consistently by the ARB staff to determine impact severity and is consistent with that 

used by the U.S. EPA.

 3. Assumptions 

This analysis uses 2006-2008 Dun and Bradstreet financial data (D&B, 2009) for a 

nationwide typical businesses in the Polish and Other Sanitation Good Manufacturing 

industry (325612 NAICS code); Pesticides and Agricultural Chemicals (325320 NAICS 

code); and Lubricant manufacturing (324191 NAICS code). For Soap and Other 

Detergent Manufacturing (NAICS code 325611) 2005-2007 Dun and Bradstreet 

financial data (D&B, 2008) were used due to lack of 2008 data. These data were used 

to calculate the ROEs before and after the subtraction of the compliance costs for a 

typical business. The calculations were based on the following assumptions: 

(1) A typical business on a nationwide basis in each industry is representative 

of a typical California business in that industry; 

(2) All affected businesses were subject to federal and State tax rates of 

35 percent and 9.3 percent respectively; and 

(3) Affected businesses are neither able to increase the prices of their 

products, nor can they lower their costs of doing business through shortterm cost-cutting measures. 

Given the limitation of available data, we believe these assumptions are reasonable for 

most businesses at least in the short run; however, they may not be applicable to all 

businesses. 

4. Results 

Table VIII-7 shows the results of our analysis of ROE. The percentage reduction in 

profitability ranges from less than 1 percent for Polish and Other Sanitation Good 

Manufacturing to less than 3 percent for Soap and Other Detergent Manufacturing. The 

mean percentage reduction in profitability is 1.6 percent. 
Technical Support Document Chapter VIII - 126 

Table VIII-7 

Summary of Decline in Return on Owners’ Equity (ROE)

NAICS Industry 

Percent Reduction 

in ROE 

325611 Soap and Other Detergent 

Manufacturing 

2.9 

325612 Polish & Other Sanitation Good 

Manufacturing 

0.8 

325320 Pesticides and Agricultural Chemicals 1.6 

324191 Lubricant Manufacturing 1.1 

Average 1.6 

Based on the estimated ROEs, we believe that overall, most affected businesses will be 

able to absorb the costs with no significant adverse impacts on their profitability. To the 

extent that at least some of the estimated costs are passed on to consumers, the impact 

on businesses’ profitability will be less than estimated here. However, the proposed 

amendments may impose economic hardship on some businesses with very little or no 

margin of profitability. 

D. Impacts on California Businesses, Consumers, and State and 

Local Agencies 

Section 11346.3 of the Government Code requires State agencies to assess the 

potential for adverse economic impacts on California business enterprises and 

individuals when proposing to adopt or amend any administrative regulation. The 

assessment must include a consideration of the impact of the proposed regulation on 

California jobs; business expansion, elimination or creation; and the ability of California 

business to compete with businesses in other states. 

1. Potential Impact on California Businesses 

Our profitability analysis shows no significant change in the average profitability of 

affected businesses that manufacture the products subject to these proposed 

amendments. Our analysis assumes that the companies absorbed the entire costs of 

compliance. However, some individual companies may experience declines in 

profitability that are different than what we predict. In these instances we believe that 

these manufacturers will pass through at least a portion of their compliance costs to 

maintain profitability. To the extent that businesses are able to pass on the increased 

costs to consumers, the adverse impact of the proposed measures would be less than 

projected in this analysis. Furthermore, the projected impact will be less if businesses 

are able to improve their operational efficiency, thus reducing their costs. 

Nevertheless, the proposed measures may impose economic hardship on some 

businesses with very little or no margin of profitability. These businesses, if hard 

pressed, can seek relief under the variance provision of the consumer products 

regulation for extensions to their compliance dates. Such extensions may provide 
Technical Support Document Chapter VIII - 127 

sufficient time to minimize the cost impacts to these businesses. Additional mitigation 

may be achieved by taking advantage of the compliance flexibility offered by the 

existing Innovative Product Provision (IPP) and the Alternative Control Plan (ACP) 

Regulation (see Section F of this chapter and section G of Chapter IX). 

 2. Potential Impact on Business Creation, Elimination or Expansion 

The proposed amendments would have no noticeable impact on the status of California 

businesses. This is because most affected businesses are expected to be able to pass 

on the bulk of the reformulation cost to consumers in terms of higher prices for their 

products. Should the proposed measures impose significant hardship on California 

businesses, temporary relief in the form of a compliance date extension under the 

variance provision may be warranted. 

On the other hand, the proposed measures may provide business opportunities for 

some California businesses or result in the creation of new businesses. California 

businesses which supply raw materials and equipment or provide consulting services to 

affected industries may benefit from increased industry spending on reformulation. 

 3. Potential Impact on Business Competitiveness 

The proposed measures would have no significant impact on the ability of California 

businesses to compete with businesses in other states. Because the proposed 

measures would apply to all businesses that manufacture or market certain consumer 

products regardless of their location, the staff’s proposal should not present any 

economic disadvantages specific to California businesses. 

Nevertheless, the proposed amendments may have an adverse impact on the 

competitive position of some small, marginal businesses in California if these 

businesses lack resources to develop commercially acceptable products in a timely 

manner. As stated above, such impacts can be mitigated to a degree with a justified 

compliance extension under the variance provision of the Consumer Products 

Regulation, or through additional regulatory flexibility afforded by the IPP or the ACP 

Regulation (see Section F of this chapter and Section G of Chapter IX). 

4. Potential Impact on California Employment 

The proposed amendments are not expected to cause a noticeable change in California 

employment and payroll. As shown in Table VIII-8, according to the U.S. Department of 

Commerce, California employment in the industries affected by the proposed 

amendments was about 3,574 in 2008, or about 6.0 percent of national employment in 

the affected industries. This represents less than 1 percent of manufacturing 

employment in California. Also, as shown in Table VIII-8, these employees generated 

about $188,488 million in payroll, or about 5.5 percent of national payroll in the affected 

industries. This also accounts for less than 1 percent of the total California 

manufacturing payroll in 2008. 
Technical Support Document Chapter VIII - 128 

Table VIII-8 

California Employment and Payroll in Affected Industries 

NAICS Number of Employees Payroll

California 

California Share as 

Percent of U.S. 

California 

(thousand dollars in 

2008) 

California Share 

as Percent of 

U.S. 

325611 952 4.4 46,606 4.1 

325612 1400 8.1 70,360 7.4 

325320 647 5.7 35,741 5.0 

324191 575 5.6 35,781 5.8 

Total 3,574 5.9 188,488 5.5 

Source: (County Business Patterns, 2008) 

5. Impacts on California Consumers 

The potential impact of the proposed amendments on consumers depends upon the 

ability of affected businesses to pass on the cost increases to consumers. However, 

competitive market forces may prevent businesses from passing their cost increases on 

to consumers. Thus, we do not expect a significant change in retail prices. 

Assuming the affected industry will pass on the entire compliance costs to consumers in 

terms of higher prices, we estimate the average price of a product (including typical 

retail mark-up) would be about $0.06. This value is different than reported earlier in the 

chapter. In the analysis here, we assume that a manufacturer will choose to spread the 

cost of compliance among all products they manufacture (not just those affected by this 

proposal). 

The proposed amendments may also affect consumers adversely if they result in 

reduced performance attributes of the products. However, this scenario is unlikely to 

occur for the following reasons. First, for the proposed limits, there are already 

complying products with a market presence. Thus, the industry already has the 

technology to manufacture compliant products that satisfy consumers. Second, 

marketers are unlikely to introduce a product which does not meet their consumers’ 

expectations. This is because such an introduction would be damaging not only to the 

product sale, but also to the sale of other products sold under the same brand name 

(impairing so-called “brand loyalty”). Finally, the Board has provided flexibility, under 

the existing consumer products program, to businesses whose situations warrant an 

extension to their compliance dates. For companies that can justify such variances, the 

additional time may afford more opportunity to explore different formulation, cost-cutting, 

performance-enhancing, or other marketing strategies which can help make the 

transition to new complying products nearly transparent to consumers. 
Technical Support Document Chapter VIII - 129 

6. Potential Impacts to California State or Local Agencies 

State agencies are required to estimate the cost or savings to any State or local agency 

and school district in accordance with instructions adopted by the Department of 

Finance. The estimate shall include any nondiscretionary cost or savings to local 

agencies and the cost or savings in federal funding to the State. 

We have determined that the proposed limits will not create costs or savings, as defined 

in Government Code section 11346.5(a)(6), to any State agency or in federal funding to 

the State, costs or mandate to any local agency or school district whether or not 

reimbursable by the State pursuant to Part 7 (commencing with section 17500), 

Division 4, title 2 of the Government Code, or other nondiscretionary savings to local 

agencies. 

We are aware that the California Prison Industry Authority (PIA) manufactures some 

products for which VOC limits are proposed. Based on their response to the 2006 

Survey, the PIA manufactures nonaerosol “General Purpose Cleaner,” “General 

Purpose Degreaser,” and “Glass Cleaner” products. All of these reported products 

already comply with the proposed VOC limits for these categories. Therefore, we 

expect no impacts on the PIA. 

ARB will have costs for enforcing the proposed amendments. It is estimated that 

beginning in fiscal year 2012-13 the Enforcement Division will require an additional 

1.5 staff. The costs for these additional resources will need to be addressed in the 

future. 

E. Other Possible Economic Impacts of Regulatory Changes 

In addition to the proposed VOC limits, there are other proposed amendments to the 

Consumer Products Regulation, some of which may have a potential economic impact 

on affected businesses. While we do not expect any significant economic impact from 

any of the proposals, it is possible that there could be some increased cost to business 

resulting from proposed changes. 

F. Mitigation of Potential Impacts Through Additional Regulatory 

Flexibility

If adopted by the Board, the proposed VOC limits will be incorporated in section 94509 

of the Consumer Products Regulation (title 17, California Code of Regulations, 

sections 94507-94517). To complement the mandatory VOC limits, the existing 

consumer products program provides compliance flexibility, through two voluntary, 

market-based programs: the IPP and the ACP Regulation. These options could be 

evaluated to minimize cost impacts. The IPP (section 94511) allows manufacturers to 

sell products that have VOC contents greater than the applicable VOC limit, provided 

they demonstrate that such products actually emit less VOCs, on a per use basis, than 

representative products that comply with the VOC limit. Using the emissions averaging 
Technical Support Document Chapter VIII - 130 

approach, the ACP is a voluntary regulation (title 17, CCR, sections 94540-94555) 

designed to allow multi-product VOC averaging as an alternative means of complying 

with the VOC limits. Additional information on these provisions is contained in 

Chapter IX, section G. 

Based on participation, it is reasonable to conclude that manufacturers are using these 

programs to provide consumers with products that meet their needs, while lowering 

costs, improving the “market value” of their products, or otherwise maintaining profit 

margins. 

Overall, most affected businesses will benefit from the IPP and the ACP Regulation. 

Both programs are completely voluntary and impose no additional costs to businesses 

to meet the requirements other than testing and reporting requirements. Manufacturers 

who take advantage of these market-based programs presumably do so because it 

costs less than direct compliance with the limits or it provides some other market 

benefits. 

According to previous analyses, the potential cost differential which might result from 

competition under the ACP between small and large firms would not necessarily cause 

extreme hardship on small firms. However, inclusion of products subject to the 

proposed limits in an ACP may affect the level of competition among companies, which 

could lead to the elimination of some marginal producers for those products. Such 

competition may also have minor impacts on California employment and payroll. 

However, the impact is expected to be positive in the long term. Any potential impacts 

on the ability of California businesses to compete with businesses in other states are 

also expected to be minimal. 

REFERENCES 

1. Air Resources Board. Initial Statement of Reasons. Proposed Amendments to 

the California Consumer Products Regulations. August 7, 2009. (ARB, 2009c) 

2. Air Resources Board. 2008 Consumer & Commercial Products Survey Update 

for Dry Clean Only Spot Removers. January 14, 2009. 

(ARB, 2009e) 

3. Air Resources Board. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation. May 9, 2008. (ARB, 2008a) 

4. Air Resources Board. 2006 Consumer & Commercial Products Survey (Including 

Aerosol Coatings Products). July 24, 2007. (ARB, 2007e) 

5. Air Resources Board. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation and the Aerosol Coatings 

Regulation. September 29, 2006. (ARB, 2006a) 
Technical Support Document Chapter VIII - 131 

6. Air Resources Board. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation: Midterm Measures I. June 6, 

1997. (ARB, 1997b) 

7. D&B Industry and Financial Consulting Services. Industry Norms & Key Business 

Ratios, Manufacturing – Volume 1. SIC #2000-2999. Three Year Edition 2008-

2009. January, 2009. (D&B, 2009) 

8. D&B Industry and Financial Consulting Services. Industry Norms & Key Business 

Ratios, Manufacturing – Volume 1. SIC #2000-2999. Three Year Edition 2007-

2008. January, 2008. (D&B, 2008) 

9. United States Census Bureau. California QuickFacts from the US Census 

Bureau. http://quickfacts.census.gov/qfd/states/06000.html. 2010. 

 (U.S. Census, 2010) 

10. United States Census Bureau. 2008 County Business Patterns (NAICS). 

(County Business Patterns, 2008) 
Technical Support Document Intentionally Blank Page - 132 
Technical Support Document Chapter IX - 133 

Chapter IX. Environmental Impacts 

In this rulemaking, ARB staff is proposing amendments to the Consumer Products 

Regulation that are designed to reduce volatile organic compound (VOC) emissions. 

Mitigation measures are also proposed to ensure that use of certain toxic air 

contaminants (TAC), greenhouse gas (GHG) compounds with higher global warming 

potential (GWP) values, and certain surfactants known to be toxic to aquatic species, 

are not used as products reformulate to meet the proposed VOC limits. 

We have evaluated the environmental impacts of the proposed amendments on 

atmospheric processes and other media. Overall, we found that the proposed 

amendments would have beneficial effects. In making this determination, we evaluated 

how the proposed amendments would impact ground-level ozone concentrations, 

particulate matter (secondary organic aerosols), climate change, stratospheric ozone 

depletion, air toxic emissions, water quality, solid waste, and energy use. 

Staff has conducted a qualitative health risk assessment that concludes that public 

health would be further protected by adoption of the proposed amendments. This 

finding is primarily related to the decrease in ground-level ozone concentrations that 

would result if the proposal were adopted. Staff has also determined that the public’s 

exposure to TACs will be reduced by the proposed mitigation measure to prohibit use of 

methylene chloride, perchloroethylene, and trichloroethylene in several product 

categories. 

Our analysis of the reasonably foreseeable environmental impacts of the methods of 

compliance is presented in subsections C through H below. Regarding reasonably 

foreseeable mitigation measures, the California Environmental Quality Act (CEQA) 

requires an agency to identify and adopt feasible mitigation measures that would 

minimize any significant adverse environmental impacts described in the environmental 

analysis. 

A. Legal Requirements Applicable to the Analysis 

 

The CEQA and ARB policy require an analysis to determine the potential adverse 

environmental impacts of proposed regulations. Because ARB’s program involving the 

adoption of regulations has been certified by the Secretary of Resources (see Public 

Resources Code section 21080.5), the CEQA environmental analysis requirements are 

allowed to be included in ARB’s Initial Statement of Reasons instead of preparing an 

environmental impact report or negative declaration. In addition, ARB will respond in 

writing to all significant environmental points raised by the public during the public 
Technical Support Document Chapter IX - 134 

review period or at the Board hearing. These responses will be contained in the Final 

Statement of Reasons for these proposed amendments.

Public Resources Code section 21159 requires that the environmental impact analysis 

conducted by ARB include the following: 

 (1) an analysis of the reasonably foreseeable environmental impacts of 

 the methods of compliance; 

 (2) an analysis of reasonably foreseeable feasible mitigation measures; 

 and, 

 (3) an analysis of reasonably foreseeable alternative means of 

 compliance with the regulation. 

Before we present our analysis of the environmental impacts of the proposal, for ease of 

the reader the proposed amendments are summarized in Part B. 

B. Summary of Proposed Amendments 

Staff is proposing to establish lower VOC limits for 11 consumer product categories. 

These limits would reduce VOC emissions by about 6.9 tons per day when fully 

effective. The proposed amendments to reduce VOC emissions would partially fulfill the 

consumer product reduction commitment contained in the 2007 State Implementation 

Plan (SIP) to meet the national ozone standard. 

Several other regulatory modifications are proposed and necessary to implement the 

new requirements. These other regulatory proposals include: 

• Modifying several definitions and proposing two new definitions; 

• Prohibiting use of methylene chloride, perchloroethylene, and trichloroethylene 

in products described as Silicone-based Multi-purpose Lubricant, Specialpurpose Lubricant, Metal Polish or Cleanser, and Spot Remover products used 

on dry clean only fabrics (other Spot Remover products are subject to an 

existing prohibition on use of these TACs). 

• Prohibiting use of compounds with GWP values at or above 150 in Flying Bug 

Insecticide, Furniture Maintenance Product, Metal Polish or Cleanser, Specialpurpose Lubricant, Spot Remover, and Wasp or Hornet Insecticide products; 

• Prohibiting use of alkylphenol ethoxylate surfactants in General Purpose Cleaner 

(nonaerosol), General Purpose Degreaser (nonaerosol), Glass Cleaner 

(nonaerosol), Heavy-duty Hand Cleaner or Soap (nonaerosol), and Oven or Grill 

Cleaner products. 

• Consolidating and clarifying some existing regulatory provisions; and 

• Modifying Test Method 310 by adding the procedures for determining the VOC 

content of Fabric Softener-Single Use Dryer Products and determining aromatic 

compound content of Paint Thinners and Multi-purpose Solvent products. 
Technical Support Document Chapter IX - 135 

C. Summary of Impacts on Atmospheric Processes 

In this section, we evaluate the impacts on atmospheric processes. The evaluation 

includes our assessment of whether the proposed amendments would have a positive, 

negative, or no impact on these atmospheric processes. 

1. Impacts of Proposed Amendments on Ground-level Ozone 

Concentrations

Enhanced ground-level ozone formation involves the interaction between VOCs and 

oxides of nitrogen (NOx) in the presence of sunlight. The rate of ozone generation is 

related closely to the amount and reactivity of VOC emissions as well as the amount of 

NOx emissions available in the atmosphere (Seinfeld and Pandis, 1998). It is one of the 

State’s most persistent air quality problems. Research has shown that, when inhaled, 

ozone can cause respiratory problems, aggravate asthma, impair the immune system, 

and cause increased risk of premature death. Ozone also adversely affects vegetation 

throughout most of California. More information on the impacts of exposure to ozone 

can be found in Chapter IV, of this Technical Support Document. 

 

a. Proposed VOC Standards: The proposed amendments are designed to reduce 

VOC emissions by about 6.9 tons per day when fully effective. Reducing these ozone 

precursor emissions will result in a positive environmental impact by lowering the 

concentrations of ground-level ozone in the atmosphere. The categories proposed for 

regulation and the corresponding VOC emission reductions are shown in Table IX-1. 

b. Proposed Toxics Prohibition: In accordance with CEQA, we are proposing a 

mitigation measure to ensure that emissions of methylene chloride, perchloroethylene, 

and trichloroethylene are not used as products are reformulated. We are proposing to 

prohibit the use of methylene chloride, perchloroethylene, and trichloroethylene in 

products described as Silicone-based Multi-purpose Lubricant, Special-purpose 

Lubricant, Metal Polish or Cleanser, and Spot Remover products used on dry clean only 

fabrics. The prohibition of these three solvents is necessary, particularly for methylene 

chloride and perchloroethylene, because they are exempt VOCs and could be used in 

reformulated products without ‘counting’ toward VOC content. However, the 

proposal to prohibit their use in these products could result in a slight increase in VOC 

emissions. This is because products containing these TACs may have to be 

reformulated using VOC solvents. Staff, therefore, evaluated the potential for VOC 

emission increases resulting from this proposal. 
Technical Support Document Chapter IX - 136 

Table IX-1 

Proposed VOC Limits, Emissions, and Reductions at Effective Date 

Product Category 

Product 

Form 

Proposed 

VOC Limit 

(weight percent)

2010 VOC 

Emissions* 

(tons per day)

Effective 

Date 

VOC 

Reductions 

at Effective 

Date 

(tons per day)

Flying Bug Insecticide Aerosol 20 0.65 12/31/2013 0.06 

Furniture Maintenance 

Product Aerosol 12 1.32 12/31/2013 0.36 

General Purpose 

Cleaner Nonaerosol 0.5 12.04 12/31/2012 3.73 

General Purpose 

Degreaser Nonaerosol 0.5 1.91 12/31/2012 1.17 

Glass Cleaner Nonaerosol 3 3.34 12/31/2012 0.41 

Heavy-duty Hand 

Cleaner or Soap Nonaerosol 1 0.79 12/31/2013 0.53 

Metal Polish or 

Cleanser Aerosol 15 0.22 12/31/2012 0.07 

Metal Polish or 

Cleanser Nonaerosol 3 0.20 12/31/2012 0.15 

Oven or Grill Cleaner Aerosol 8 0.08 12/31/2012 >0.0 

Oven or Grill Cleaner Nonaerosol 4 0.24 12/31/2012 -0.12 

Special-purpose 

Lubricant Aerosol 25 0.26 12/31/2012 0.10 

Special-purpose 

Lubricant Nonaerosol 3 0.18 12/31/2012 0.13 

Spot Remover (Dry 

Clean Only) Aerosol 15 >0.0 12/31/2012 >0.0 

Spot Remover (Dry 

Clean Only) Nonaerosol 3 0.17 12/31/2012 0.17 

Wasp or Hornet 

Insecticide Aerosol 10 0.31 12/31/2013 0.14 

Total Emissions 

2010 21.7 tons per day

Total VOC 

Reductions 

Creditable Toward 

2007 SIP 

6.7 tons per day 

Total VOC 

Reductions 

Creditable Toward 

Future 

Commitment 

0.2 tons per day 

* Survey emissions adjusted for market coverage and grown to the 2010 calendar year 

The emissions of chlorinated solvents in these products totals about 0.1 tons per day. 

All but a small fraction of this total (< 1 percent) is emissions of trichloroethylene. 

Because this solvent is a VOC, as a matter of course, its use would essentially be 
Technical Support Document Chapter IX - 137 

precluded by imposition of the VOC limits. Therefore, we have concluded that VOC 

emissions would not increase as a result of the proposed prohibitions. The proposed 

prohibition, then, would have no adverse impact on ground-level ozone concentrations. 

If there were to be a very small increase in VOC emissions we believe that preventing 

exposure to these TAC solvents outweighs the very small VOC emission increase that 

may occur. 

c. Proposed Global Warming Potential Limits: In accordance with CEQA, we are 

proposing a global warming potential (GWP) limit of 150 for compounds used in Flying 

Bug Insecticide, Furniture Maintenance Product, Metal Polish or Cleanser, Specialpurpose Lubricant, Spot Remover, and Wasp or Hornet Insecticide products. Absent 

this provision, use of several compounds with GWP values at or above 150 could result 

in some small additional ozone reduction benefit if they were to be used in 

reformulations. 

d. Proposed Prohibition on Use of Alkylphenol Ethoxylate Surfactants: We are 

proposing to prohibit the use of alkylphenol ethoxylate surfactants in Oven or Grill 

Cleaner products and in the nonaerosol forms of General Purpose Cleaner, General 

Purpose Degreaser, Glass Cleaner, and Heavy-duty Hand Cleaner or Soap products. 

We do not expect this proposal to have an impact on ground level ozone 

concentrations. While this prohibition would eliminate one potential reformulation 

option, many other surfactants are suitable, and readily available, for use in these 

categories, making the use of alkylphenol ethoxylate surfactants unnecessary. These 

surfactants are considered low vapor pressure (LVP) VOC compounds and do not count 

toward a product’s VOC content. Because of the many alternatives available, 

precluding the use of alkylphenol ethoxylate surfactants does not necessitate raising the 

proposed VOC limit. 

e. Proposed New and Modified Definitions: We expect no impact on ground-level 

ozone concentrations resulting from the proposed new and modified definitions. These 

definitions are necessary to describe or clarify the types of products that are subject to 

the VOC limits, but do not themselves impose any requirements that would impact 

ground level ozone concentrations. 

f. Other Proposed Amendments: A number of modifications to the regulatory 

language are proposed to consolidate various toxic prohibitions, consolidate GWP 

limits, and to clarify other provisions of the regulation. These clarifications may result in 

an incremental improvement in compliance and therefore, could result in an additional 

ozone reduction benefit. 

g. Proposed Changes to Method 310: The proposed changes to Method 310 would 

add the procedures for determining the VOC content of Fabric Softener-Single Use 

Dryer Products and determining aromatic compound content of Paint Thinner and Multipurpose Solvent products. These procedures themselves are expected to have no 

impact on ground level ozone concentrations. However, the proposals would allow 

enforcement of requirements designed to reduce ozone concentrations. 
Technical Support Document Chapter IX - 138 

2. Impacts of Proposed Amendments on Particulate Matter (Secondary 

Organic Aerosols) 

Fine particulate matter (PM) is prevalent in the urban atmosphere (see, for example, 

Pandis et al., 1992). Ambient PM, especially those with diameters less than two and a 

half micrometers (PM2.5), is known to have negative impacts on human health (Schwartz 

et al., 1996; Moolgavkar and Luebeck, 1996). Similarly to ozone, PM can be formed via 

atmospheric oxidation of organic compounds (Finlayson-Pitts and Pitts, 2000). 

Modeling techniques to determine the amount of ozone as well as the amount of 

aerosol formed from a VOC have been established (Bowman et al., 1994), and a 

concept similar to maximum incremental reactivity is being applied to quantitatively 

assess the aerosol formation potential of a VOC (i.e. incremental aerosol reactivity) 

(Griffin et al., 1999). More information on the health impacts of PM is found in 

Chapter IV of the report. 

Although most organic compounds contribute to ozone formation, SOA is usually 

formed from photooxidation of VOCs with carbon numbers equal to six or more 

(Seinfeld and Pandis, 1998). It has also been shown that aromatic compounds are 

more likely to participate in the formation of SOA than are alkanes (Grosjean, 1992; 

Pandis et al., 1992). In other words, only chemicals that react fast enough in the 

atmosphere will generate sufficient amounts of low volatility products for forming 

aerosols. The analysis of the impact on SOA formation resulting from implementing the 

proposed VOC limits is detailed below. 

In general terms, the potential to form SOA among common classes of VOCs used in 

consumer products could be described by the following order, with the lower molecular 

weight alkanes and ketones being least likely: 

Least Likely Lower molecular weight alkanes and ketones (6 carbons or 

less) 

Higher molecular weight alkanes 

Higher molecular weight aromatics (polysubstituted benzenes) 

More Likely Lower molecular weight aromatics (C6 - C8 compounds) 

a. Proposed VOC Standards: The analysis of the potential impact on PM formation 

from the proposed VOC limits assumes that to meet the proposed limits will require 

replacing about 6.9 tons per day of VOC ingredients with 6.9 tons per day of non-VOC 

ingredients or exempt VOCs. To meet the proposed VOC limits, manufacturers 

generally have five reformulation options: use of exempt VOCs, such as acetone or 

methyl acetate; use of LVP-VOC solvents; use of surfactants; use of water; increasing 

‘solids’ content; or use of non-VOC propellants. Substitution for VOCs with water, 

higher solids content, or non-VOC propellants would likely result in a small reduction in 

SOA formation. The most likely exempt VOC solvents that could be used to comply, 

acetone and methyl acetate, both having three carbon atoms, have little potential to 

contribute to SOA formation. Indeed, it has been predicted that there would be no SOA 
Technical Support Document Chapter IX - 139 

yield from acetone (Pandis et al., 1992). Hence, use of these compounds could also 

result in a reduction in SOA. 

If manufacturers were to reduce overall VOC content to comply with the proposed limits 

by reformulating with smaller amounts of stronger VOC solvents could result in 

increased SOA formation. This is because the commonly used stronger solvents are 

aromatic compounds, such as xylenes and toluene, which are known to have higher 

SOA potentials than other commonly used VOCs. In the categories proposed for 

regulation we do not believe that aromatic compounds are a likely reformulation 

pathway. Therefore, we expect no increase in SOA due to use of aromatic compounds. 

However, substitution of LVP-VOC solvents for VOCs could result in a slight SOA 

increase (Chan et al., 2009). 

Because we can not predict how manufacturers will choose to reformulate, we can not 

fully evaluate the potential for increased SOA formation. However, it is likely to be only 

a slight potential for increase, if any, due to the variety of reformulation options 

available. At any rate, it will not be a significant adverse impact. Additionally, any 

reformulations that result in increased SOA would likely be offset by reformulations 

resulting in lower SOA. For example, one potential reformulation option for Heavy Duty 

Hand Cleaner or Soap products would be to substitute an LVP-VOC hydrocarbon 

solvent for terpenes such as d-limonene, a VOC. D-limonene can react with ozone to 

form a variety of secondary products including formaldehyde and SOA (Singer et al., 

2006). Potential use of this proposed reformulation option could result in lower SOA 

formation. We will continue to monitor implementation of the regulation and reassess 

the impacts as more data quantitative data on SOA formation potentials become 

available. 

b. Proposed Toxics Prohibition: The proposal to prohibit use of methylene chloride, 

perchloroethylene, and trichloroethylene in products described as Silicone-based Multipurpose Lubricant, Special-purpose Lubricant, Metal Polish or Cleanser, and Spot 

Remover products used on dry clean only fabrics should have no or negligible impacts 

on SOA formation. These compounds are not expected to be potent participants in 

SOA formation because they are small molecules and have only one or two carbon 

atoms. By precluding use of these solvents in current formulations and as a 

reformulation option, we would potentially relinquish some additional small reduction in 

the production of SOA. For example, if these TAC solvents, rather than LVP-VOC 

solvents were to be used, the SOA formation potential of reformulated products could 

be slightly lower. However, we believe that preventing the public’s exposure to these 

TAC solvents, which are potential human carcinogens, outweighs the uncertain small 

potential for a reduction in SOA. 

 

c. Proposed Global Warming Potential Limits: The proposed GWP limit of 150 for 

compounds used in the reformulation of Flying Bug Insecticide, Furniture Maintenance 

Product, Metal Polish or Cleanser, Special-purpose Lubricant, Spot Remover, and 

Wasp or Hornet Insecticide products is expected to have negligible or no impact on PM 

or SOA formation. We do not believe that compounds with GWP values at or above 
Technical Support Document Chapter IX - 140 

150 could be substituted in such a way to significantly change the amount of SOA 

formed from these categories. 

d. Proposed Prohibition on Use of Alkylphenol Ethoxylate Surfactants: We are 

proposing to prohibit the use of octylphenol and nonylphenol ethoxylate surfactants in 

Oven or Grill Cleaner products and in the nonaerosol forms of General Purpose 

Cleaner, General Purpose Degreaser, Glass Cleaner, and Heavy-duty Hand Cleaner or 

Soap products. We expect this proposal to have a neutral impact on SOA formation. 

Alkylphenol ethoxylate surfactants, as well as other surfactants that would be used in 

these categories, are considered LVP-VOC compounds and do not count toward a 

product’s VOC content. It is also unlikely that these large molecules have an air fate. 

Therefore, regardless of which surfactant is selected, the impacts on SOA, if any, are 

likely similar. 

e. Proposed New and Modified Definitions: We expect no impact on SOA formation 

resulting from the proposed new and modified definitions. These definitions are 

necessary to describe or clarify the types of products that are subject to the VOC limits 

but do not themselves impose any requirements that would affect SOA formation. 

f. Other Proposed Amendments: A number of modifications to the regulatory 

language are proposed to consolidate various toxic prohibitions, consolidate GWP 

limits, and to clarify other provisions of the regulation. These consolidations of existing 

requirements, and language clarifications do not result in any change to the 

environment. Therefore, we expect these amendments to have no impact on SOA 

formation. 

g. Proposed Changes to Method 310: The proposed changes to Method 310 would 

add the procedures for determining the VOC content of Fabric Softener-Single Use 

Dryer Products and determining aromatic compound content of Paint Thinner and Multipurpose Solvent products. These procedures themselves impose no requirements and 

should have no impact on SOA formation. 

3. Impacts of Proposed Amendments on Climate Change 

Climate change or global warming is the process whereby emissions of anthropogenic 

pollutants, together with other naturally-occurring gases, absorb infrared radiation in the 

atmosphere, leading to increases in the overall average global temperature. 

Gases in the atmosphere can contribute to the greenhouse effect both directly and 

indirectly. Direct effects occur when the gas itself is a GHG. Indirect radiative forcing 

occurs when chemical transformations of the original gas produce other GHGs, when a 

gas influences the atmospheric lifetimes of methane, and/or when a gas affects 

atmospheric processes that alter the radiative balance of the earth (e.g., affect cloud 

formation). 
Technical Support Document Chapter IX - 141 

Compounds with direct effects include VOCs, carbon dioxide (CO2), hydrofluorocarbons 

(HFCs), hydrofluoroethers (HFEs), and hydrochlorofluorocarbons (HCFCs). Even 

though VOCs have direct effects, they are considered GHGs primarily because of their 

role in creating ozone and in prolonging the life of methane in the atmosphere, although 

the effect varies depending on local air quality. More information on climate change can 

be found in Chapter IV of this report. 

a. Proposed VOC Standards: As described above, VOCs are considered GHGs 

because of their role in ground-level ozone formation. However, because these 

amendments would reduce the total amount of VOCs, and thereby ground-level ozone 

concentrations, the proposed VOC limits should have an overall positive impact on 

climate change. However, two reformulation options may lead to very slight increases 

in GHG emissions. These are discussed below. 

To meet the proposed VOC limits, CO2, to a limited extent, could be used to replace 

hydrocarbon propellants in some consumer product categories. The survey data 

indicate that CO2 is already used in certain consumer products proposed for regulation, 

including Special-purpose Lubricant and Wasp or Hornet Insecticide products. In these 

categories CO2 use is likely to increase as manufacturers reformulate to meet the lower 

proposed VOC limits. In other categories with aerosol product forms, CO2 may also be 

a reformulation pathway. Even though CO2 has a direct impact on climate change, cobenefits are expected to the extent that CO2 replaces VOC propellants in consumer 

products. Specifically, less ozone and methane will be formed. Further, the contribution 

of CO2 to global warming is likely less than that of the VOC being replaced. In addition, 

most CO2 used as propellant is a recycled by-product of existing processes and, 

therefore, does not increase global warming from a lifecycle standpoint (ARB, 1999). 

Another reformulation path for the aerosol products may be to replace some or all the 

typical hydrocarbon propellants with HFC-152a or HFC-134a. These compounds are 

exempt VOCs, but are global warming compounds. HFC-152a and HFC-134a have 

global warming potentials of 140 and 1,300, respectively. Limited use of the moderately 

warming compound HFC-152a was reported in several categories proposed for 

regulation. No use of the higher warming HFC-134a was reported. Staff has proposed 

limits that are achievable without the use of either of these exempt propellants. 

Because of this, along with the substantially higher cost of these propellants, we do not 

expect emissions of HFC-152a to increase. As described later in section E of this 

chapter, to ensure that reformulating to meet the VOC limits does not result in an 

adverse impact on climate change we are proposing to preclude use of compounds with 

GWP values at or above 150. This proposed mitigation measure will ensure that there 

would be no additional impact on climate change from use of these global warming 

compounds. 

b. Proposed Toxics Prohibition: The proposal to prohibit use of methylene chloride, 

perchloroethylene, and trichloroethylene in products described as Silicone-based Multipurpose Lubricant, Special-purpose Lubricant, Metal Polish or Cleanser, and Spot 

Remover products used on dry clean only fabrics will likely have no or negligible 
Technical Support Document Chapter IX - 142 

impacts on climate change. Even if VOCs or compounds with GWP values less than 

150 were used to replace TACs in these products there would be a negligible increase 

in global warming compound emissions because the total amount of these TACs is less 

than 0.1 tons per day. 

c. Proposed Global Warming Potential Limits: The proposed GWP limit of 150 for 

compounds used in Flying Bug Insecticide, Furniture Maintenance Product, Metal Polish 

or Cleanser, Spot Remover, Special-purpose Lubricant, and Wasp or Hornet Insecticide 

products is designed to minimize the climate change impacts of the emissions from 

products in these categories. Therefore, we expect the proposal to have overall 

beneficial impacts on climate change by preventing use of compounds with higher GWP 

values. 

d. Proposed Prohibition on Use of Ethoxylate Surfactants: We are proposing to 

prohibit the use of alkylphenol ethoxylate surfactants in Oven or Grill Cleaner products 

and in the nonaerosol forms of General Purpose Cleaner, General Purpose Degreaser, 

Glass Cleaner, and Heavy-duty Hand Cleaner or Soap products. We do not expect this 

proposal to have an impact on climate change because the compounds that would be 

used in place of the alkylphenol ethoxylate surfactants are not global warming 

compounds. 

e. Proposed New and Modified Definitions: We expect no impact on climate 

change resulting from the proposed new and modified definitions. These definitions are 

necessary to describe or clarify the types of products that are subject to the VOC limits 

but do not themselves impose any requirements that would affect climate change. 

f. Other Proposed Amendments: A number of modifications to the regulatory 

language are proposed to consolidate various toxic prohibitions, consolidate GWP 

limits, and to clarify other provisions of the regulation. These consolidations of existing 

requirements, and language clarifications do not result in any change to the 

environment. Therefore we expect these amendments to have no impact on climate 

change. 

g. Proposed Changes to Method 310: The proposed changes to Method 310 would 

add the procedures for determining the VOC content of Fabric Softener-Single Use 

Dryer Products and determining aromatic compound content of Paint Thinner and Multipurpose Solvent products. These procedures themselves impose no requirements and 

should have no impact on climate change. 

4. Impacts of Proposed Amendments on Stratospheric Ozone Depletion

The stratospheric ozone layer shields the earth from harmful ultraviolet (UV) radiation. 

Depletion of the earth’s ozone layer allows a higher penetration of UV radiation to the 

earth's surface. This increase in UV radiation penetration leads to a greater incidence 

of skin cancer, cataracts, and impaired immune systems. Reduced crop yields and 

diminished ocean productivity are also expected. Because the chemical reactions, 
Technical Support Document Chapter IX - 143 

which form ground-level ozone are driven by UV radiation, it is conceivable that a 

reduction in stratospheric ozone concentrations may also result in an increase in the 

formation of photochemical smog because of the increased levels of UV radiation on the 

earth’s surface (ARB, 2000). The chemicals most implicated as causing stratospheric 

ozone depletion are chlorofluorocarbons (CFCs), HCFCs, and halons (U.S. EPA, 

2003a). Specifically, the chlorine or bromine atoms released by photolysis of the 

compounds react in chain reactions leading to the catalytic destruction of ozone 

(Finlayson-Pitts and Pitts, 2000). 

Solar irradiation in the stratosphere contains sufficient UV light to break down CFCs and 

HCFCs to yield chlorine atoms that convert ozone to molecular oxygen. However, this 

UV light is not strong enough to break down HFCs and HFEs to create fluorine atoms. 

In addition, the molecular structure of HFCs and HFEs includes hydrogen atoms, which 

renders them susceptible to attack by hydroxyl radicals in the troposphere. Therefore, 

these chemicals have a relatively short atmospheric lifetime, which does not allow any 

appreciable amounts to penetrate into the stratosphere (ARB, 2008d). 

To address stratospheric ozone depletion, the Montreal protocol was enacted in 1989, 

to phase out a number of CFCs, HCFCs, and halons. As a signatory of this protocol, 

the United States, in the Federal Clean Air Act of 1990 established timetables for 

ceasing production (see part 40, Code of Federal Regulations, section 602). In general, 

the protocol establishes dates by which certain compounds can no longer be 

manufactured; however, existing stocks can continue to be used in some applications 

until exhausted. 

a. Proposed VOC Standards: Reducing VOCs will have no impact on stratospheric 

ozone depletion. As products reformulate to meet the proposed VOC limits, provisions 

in the Consumer Products Regulation (see section 94509(e)) already prohibit the use of 

various stratospheric ozone depleting compounds. This provision ensures there will be 

no increased use of stratospheric ozone depleting compounds. 

b. Proposed Toxics Prohibition: The proposal to prohibit use of methylene chloride, 

perchloroethylene, and trichloroethylene in products described as Silicone-based Multipurpose Lubricant, Special-purpose Lubricant, Metal Polish or Cleanser, and Spot 

Remover products used on dry clean only fabrics should have no impact on 

stratospheric ozone depletion. In order to comply with this prohibition, VOCs may 

replace these TACs in reformulated products. VOCs are not stratospheric ozone 

depleting compounds. It should also be noted that manufacturers are precluded from 

reformulating with stratospheric ozone depleting compounds because use of these 

compounds is already restricted by the Consumer Products Regulation (see section 

94509(e)). 

c. Proposed Global Warming Potential Limits: The proposed GWP limit of 150 for 

compounds used in Flying Bug Insecticide, Furniture Maintenance Product, Metal Polish 

or Cleanser, Spot Remover, Special-purpose Lubricant, and Wasp or Hornet Insecticide 

products will ensure that these products’ emissions do not contribute to further depletion 
Technical Support Document Chapter IX - 144 

of the stratospheric ozone layer. This is because some compounds with higher GWPs 

are also stratospheric ozone depleting compounds. 

d. Proposed Prohibition on Use of Alkylphenol Ethoxylate Surfactants: We are 

proposing to prohibit the use of alkylphenol ethoxylate surfactants in Oven or Grill 

Cleaner products and in the nonaerosol forms of General Purpose Cleaner, General 

Purpose Degreaser, Glass Cleaner, and Heavy-duty Hand Cleaner or Soap products. 

We do not expect this proposal to have an impact on stratospheric ozone depletion 

because the compounds that would be used in place of the alkylphenol ethoxylate 

surfactants are not stratospheric ozone depleting compounds. 

e. Proposed New and Modified Definitions: We expect no impact on stratospheric 

ozone depletion resulting from the proposed new and modified definitions. These 

definitions are necessary to describe or clarify the types of products that are subject to 

the VOC limits but do not themselves impose any requirements that would have an 

impact on stratospheric ozone depletion. 

f. Other Proposed Amendments: A number of modifications to the regulatory 

language are proposed to consolidate various toxic prohibitions, consolidate GWP 

limits, and to clarify other provisions of the regulation. These consolidations of existing 

requirements, and language clarifications do not result in any change to the 

environment. Therefore, we expect these amendments to have no impact on 

stratospheric ozone depletion. 

g. Proposed Changes to Method 310: The proposed changes to Method 310 would 

add the procedures for determining the VOC content of Fabric Softener-Single Use 

Dryer Products and determining aromatic compound content of Paint Thinner and Multipurpose Solvent products. These procedures themselves impose no requirements and 

should have no impact on stratospheric ozone depletion. 

D. Other Potential Environmental Impacts

In section C we evaluated the proposed amendments’ impacts on air quality. In this 

section we provide an analysis as to whether the proposed amendments would impact 

other media. 

1. Impacts of Proposed Amendments on Solid Waste Disposal 

Consumer products contribute to the solid waste stream by virtue of the packaging, 

container, or mechanism such as towelettes or “wipes” used to deliver the product. 

Therefore, we evaluated the potential impacts of the proposed amendments on the solid 

waste stream. 

a. Proposed VOC Standards: We do not expect an adverse impact on solid waste 

disposal from the proposed amendments relating to VOC limits. Most of the 

reformulation options include increasing production of existing complying products, 
Technical Support Document Chapter IX - 145 

using water-based formulations, or replacing VOC solvents with exempt compounds or 

LVP-VOC solvents. These reformulation options are not expected to alter the current 

methods of packaging, container, delivery mechanism. 

b. Proposed Toxics Prohibition: The proposal to prohibit use of methylene chloride, 

perchloroethylene, and trichloroethylene in products described as Silicone-based Multipurpose Lubricant, Special-purpose Lubricant, Metal Polish or Cleanser, and Spot 

Remover products used on dry clean only fabrics should have no impact on solid waste 

disposal because the compounds used to replace them require no different packaging, 

or additional packaging. In addition, this proposed prohibition on use of chlorinated 

TAC solvents should ensure that there is no increased hazardous waste disposal. 

c. Proposed Global Warming Potential Limits: The proposed GWP limit of 150 for 

compounds used in Flying Bug Insecticide, Furniture Maintenance Product, Metal Polish 

or Cleanser, Spot Remover, Special-purpose Lubricant, Wasp or Hornet Insecticide 

products is expected to have no impact on waste disposal. Implementing this proposal 

does not cause a change in the manner in which products are to be disposed. 

d. Proposed Prohibition on Use of Ethoxylate Surfactants: We are proposing to 

prohibit the use of alkylphenol ethoxylate surfactants in Oven or Grill Cleaner products 

and in the nonaerosol forms of General Purpose Cleaner, General Purpose Degreaser, 

Glass Cleaner, and Heavy-duty Hand Cleaner or Soap products. We do not expect this 

proposal to have an impact on solid waste disposal because the compounds that would 

be used in place of the alkylphenol ethoxylate surfactants are not disposed of in a 

manner that would be different. 

e. Proposed New and Modified Definitions: We expect no impact on solid waste 

disposal resulting from the proposed new and modified definitions. These definitions 

are necessary to describe or clarify the types of products that are subject to the VOC 

limits but do not themselves impose any requirements that would affect solid waste 

disposal. 

f. Other Proposed Amendments: A number of modifications to the regulatory 

language are proposed to consolidate various toxic prohibitions, consolidate GWP 

limits, and to clarify other provisions of the regulation. These consolidations of existing 

requirements, and language clarifications do not result in any change to the 

environment. Therefore, we expect these amendments to have no impact on solid 

waste disposal. 

g. Proposed Changes to Method 310: The proposed changes to Method 310 would 

add the procedures for determining the VOC content of Fabric Softener-Single Use 

Dryer Products and determining aromatic compound content of Paint Thinner and Multipurpose Solvent products. These procedures themselves impose no requirements and 

should have no impact on solid waste disposal. 
Technical Support Document Chapter IX - 146 

2. Impacts of Proposed Amendments on Water Quality 

Because of how consumer products are used there are potential water quality impacts. 

For example many products are diluted with water and used with a mop and bucket. 

This generally results in excess product that is disposed of “down the drain.” Therefore, 

we evaluated the impacts of the proposed amendments on water quality. 

a. Proposed VOC Standards

Overall, reducing VOCs should have no impact on water quality and could ultimately 

result in a positive impact. As products reformulate to meet the proposed VOC limits, to 

a limited extent, water may replace VOCs in some products. This would have a positive 

impact on water quality by reducing the quantity of VOCs that might be introduced to the 

water supply. If exempt solvent compounds replace VOCs in reformulated products, 

there should be no increased impact. This is because as far as water chemistry is 

concerned, VOCs and VOC exempt solvents are similar. It is also true that many VOCs 

are biodegraded as they pass through the waste water stream. 

Staff has determined that use of surfactants is a viable reformulation pathway for 

several cleaning products. Generally, surfactants are LVP-VOC ingredients. 

Depending on the type of surfactant chosen there could be water quality impacts if 

these surfactants are washed “down the drain.” In particular, the alkylphenol ethoxylate 

surfactants are known to have toxic impacts on aquatic species. They are estrogenic. 

In light of this, staff is proposing a specific mitigation measure as described in subpart 

‘d’ of this section and in section E. 

One reformulation option for nonaerosol Heavy-duty Hand Cleaner or Soap products 

could result in an increase in the use of abrasive ingredients. Increased amounts of 

abrasive ingredients will potentially be washed “down the drain,” impacting water 

treatment and increasing solid waste. Therefore, staff evaluated the potential that 

increased use of abrasives could impact water quality. We determined that there is no 

reason to believe that the reformulation of nonaerosol Heavy-duty Hand Cleaner or 

Soap products would have significant adverse impacts on water treatment systems. 

Approximately 60 percent of the 113 products that comply with the proposed VOC limit 

of 1 percent by weight contain abrasives with 12 products containing less than 1 percent 

by weight. About half of the complying products contain very little or no abrasive 

ingredients, indicating that product reformulations that do not rely on increase use of 

abrasives are just as likely. Moreover, should manufacturers choose to use abrasive 

ingredients, biodegradable materials such as crushed nut shells, seeds or corn cobs are 

options. 

b. Proposed Toxics Prohibition: The proposal to prohibit use of methylene chloride, 

perchloroethylene, and trichloroethylene in products described as Silicone-based Multipurpose Lubricant, Special-purpose Lubricant, Metal Polish or Cleanser, and Spot 

Remover products for use on dry clean only fabrics should have a positive impact on 

water quality by ensuring that these TACs will not enter the water system and 
Technical Support Document Chapter IX - 147 

subsequently effect influent and effluent concentrations at publicly owned treatment 

works (POTW). 

c. Proposed Global Warming Potential Limits: The proposed GWP limit of 150 for 

compounds used in Flying Bug Insecticide, Furniture Maintenance Product, Metal Polish 

or Cleanser, Spot Remover, Special-purpose Lubricant, Wasp or Hornet Insecticide 

products is expected to have no impact on water quality. We are not aware of 

compounds with GWP values at or greater than 150 that could lead to improving water 

quality if they were to be used in formulations. Therefore, we expect no adverse 

impacts from this proposed limit. 

d. Proposed Prohibition on Use of Alkylphenol Ethoxylate Surfactants: We are 

proposing to prohibit the use of alkylphenol ethoxylate surfactants in Oven or Grill 

Cleaner products and in the nonaerosol forms of General Purpose Cleaner, General 

Purpose Degreaser, Glass Cleaner, and Heavy-duty Hand Cleaner or Soap products. 

We expect this proposal to have a beneficial impact on water quality because amounts 

of these aquatic toxicants would be reduced. The need for this prohibition is set forth in 

section E of this chapter. 

e. Proposed New and Modified Definitions: We expect no impact on water quality 

resulting from the proposed new and modified definitions. These definitions are 

necessary to describe or clarify the types of products that are subject to the VOC limits 

but do not themselves impose any requirements that would affect water quality. 

f. Other Proposed Amendments: A number of modifications to the regulatory 

language are proposed to consolidate various toxic prohibitions, consolidate GWP 

limits, and to clarify other provisions of the regulation. These consolidations of existing 

requirements, and language clarifications do not result in any change to the 

environment. Therefore, we expect these amendments to have no impact on water 

quality. 

g. Proposed Changes to Method 310: The proposed changes to Method 310 would 

add the procedures for determining the VOC content of Fabric Softener-Single Use 

Dryer Products and determining aromatic compound content of Paint Thinner and Multipurpose Solvent products. These procedures themselves impose no requirements and 

should have no impact on water quality. 

3. Impacts of Proposed Amendments on Energy 

As products are reformulated to comply with the proposed amendments staff evaluated, 

to the extent feasible, whether the reformulation process or finished products would 

impact energy consumption. Among the processes to consider would be transportation 

related or raw ingredient manufacturing costs. 

a. Proposed VOC Standards: Reformulation of products to meet the proposed 

VOC limits should have no impact on energy use because we do not expect the 
Technical Support Document Chapter IX - 148 

manufacturing processes or shipping practices to be changed. We also do not expect 

the manufacture of compounds used in reformulations to result in energy use above the 

current situation because the types of chemicals predicted to be used are similar to 

those being replaced. 

b. Proposed Toxics Prohibition: The proposal to prohibit use of methylene chloride, 

perchloroethylene, and trichloroethylene in products described as Silicone-based Multipurpose Lubricant, Special-purpose Lubricant, Metal Polish or Cleanser, and Spot 

Remover products used on dry clean only fabrics is expected to have negligible, or no 

impact on energy use. Absent the proposed prohibition, we are not aware of how these 

compounds could be used in a manner that would cause an appreciable change in 

energy use or savings. 

c. Proposed Global Warming Potential Limits: The proposed GWP limit of 150 for 

compounds used in aerosol Flying Bug Insecticide, Furniture Maintenance Product, 

Metal Polish or Cleanser, Spot Remover, Special-purpose Lubricant, Wasp or Hornet 

Insecticide products is expected to have no impact on energy use. In the absence of 

this provision we are not aware of how these compounds could be used in 

reformulations that would cause an appreciable change in energy use or savings. 

d. Proposed Prohibition on Use of Ethoxylate Surfactants: We are proposing to 

prohibit the use of alkylphenol ethoxylate surfactants in Oven or Grill Cleaner products 

and in the nonaerosol forms of General Purpose Cleaner, General Purpose Degreaser, 

Glass Cleaner, and Heavy-duty Hand Cleaner or Soap products. We do not expect this 

proposal to have an impact on energy use because the compounds that would be used 

in place of the alkylphenol ethoxylate surfactants are similar. 

e. Proposed New and Modified Definitions: We expect no impact on energy use 

resulting from the proposed new and modified definitions. These definitions are 

necessary to describe or clarify the types of products that are subject to the VOC limits 

but do not themselves impose any requirements that would affect energy use. 

f. Other Proposed Amendments: A number of modifications to the regulatory 

language are proposed to consolidate various toxic prohibitions, consolidate GWP 

limits, and to clarify other provisions of the regulation. These consolidations of existing 

requirements, and language clarifications do not impose requirements that would result 

in energy use that is different from energy use that would occur absent these provisions. 

Therefore, we expect these amendments to cause no appreciable change in energy use 

or savings. 

g. Proposed Changes to Method 310: The proposed changes to Method 310 would 

add the procedures for determining the VOC content of Fabric Softener-Single Use 

Dryer Products and determining aromatic compound content of Paint Thinner and Multipurpose Solvent products. These procedures themselves impose no requirements and 

should have no impact on energy use. 
Technical Support Document Chapter IX - 149 

E. Analysis of Need for Reasonably Foreseeable Mitigation 

Measures 

As part of our obligations under CEQA, ARB staff is required to evaluate and mitigate 

potential adverse environmental impacts resulting from regulatory proposals. Also, 

pursuant to Health and Safety Code section 39650 et seq., the ARB is required to 

identify and control TACs. The Health and Safety Code defines a TAC as “...an air 

pollutant which may cause or contribute to an increase in mortality or serious illness, or 

which may pose a hazard to human health.” Moreover, in accordance with section 

39666 of the Health and Safety Code, for TACs for which no safe exposure threshold 

has been established, the ARB is required to “.... reduce emissions to the lowest level 

achievable through application of best available control technology or a more effective 

control method....” 

Several chemicals currently used in the products for which VOC limits are proposed, or 

that are potential reformulation options, are known to have health impacts, or otherwise 

adversely impact the environment. An increased or continued use of these compounds 

in the categories proposed for regulation could lead to potential adverse environmental 

impacts. Because of this, ARB staff evaluated this potential to determine if use of these 

compounds, at the concentrations predicted, could result in adverse public or personal 

exposures or result in any other potential adverse environmental impact. Staff’s 

analyses follow. 

1. Proposed Mitigation Measure to Prohibit Use of Certain Chlorinated 

TACs 

Use of three chlorinated solvents, methylene chloride, perchloroethylene, and 

trichloroethylene, was reported as currently used in several categories proposed for 

regulation. In review of reformulation approaches for several other categories staff 

determined that these compounds, although not currently used, could be used as 

products reformulate to meet the proposed VOC limits. These chlorinated solvents 

have been identified as TACs because they are possible or probable human 

carcinogens. 

Two of these TACs, methylene chloride and perchloroethylene, are specifically 

exempted from the VOC definition (see section 94508a) in recognition of their very low 

ozone-forming capability. Thus, the potential exists that to meet VOC limits, 

manufacturers could reformulate using these exempt VOC TACs leading to an adverse 

impact. Because these two compounds are TACs we are proposing a specific 

mitigation measure to address their use. While trichloroethylene is regulated as a VOC, 

such that its use should not increase as products reformulate to meet VOC limits, 

because it is a TAC we believe a mitigation measure is necessary to ensure that it is not 

used. 

For specific information related to the toxicity of these compounds the reader is referred 

to the following documents: 
Technical Support Document Chapter IX - 150 

 a. Initial Statement of Reasons for the Proposed Airborne Toxic Control 

Measure for Emissions of Chlorinated Toxic Air Contaminants from 

Automotive Maintenance and Repair Activities. March 10, 2000. 

(ARB, 2000). 

 b. Initial Statement of Reasons for the Proposed Amendments to the 

California Aerosol Coating Products, Antiperspirants and Deodorants, and 

Consumer Products Regulations, Test Method 310, and Airborne Toxic 

Control Measure for Para-Dichlorobenzene Solid Air Fresheners and 

Toilet/Urinal Care Products. May 7, 2004. (ARB, 2004b). 

c. Initial Statement of Reasons for the Proposed Amendments to the 

California Consumer Products Regulations. May 9, 2008. (ARB, 2008a) 

In this rulemaking staff is proposing to prohibit the use of methylene chloride, 

perchloroethylene, and trichloroethylene in Silicone-based Multi-purpose Lubricant, 

Special-purpose Lubricant, Metal Polish or Cleanser, and Spot Remover products for 

use on dry clean only fabrics. The proposed prohibitions would be contained in section 

94509(m) of the regulation. Implementing this provision would reduce emissions of 

methylene chloride, perchloroethylene, and trichloroethylene by about 0.1 tons per day 

and prevent their use in reformulated products. 

In each category where we are proposing this prohibition, staff has determined that use 

of these TAC compounds poses an unnecessary health hazard. Therefore, the 

proposed prohibitions are necessary to mitigate potential adverse impacts that would 

result from implementing VOC limits for these categories. The prohibitions would also 

align with State law that requires use of best available control technology in instances 

where no safe exposure threshold is known. 

Staff also determined that a variety of reformulation technologies exist such that use of 

these TACs is not necessary in these categories. More detailed information on 

alternative products and chemicals that can be used to reformulate products such that 

use of methylene chloride, perchloroethylene, and trichloroethylene is unnecessary is 

contained in Chapter VII. 

The proposed prohibition is a mitigation measure under CEQA (Public Resources Code 

section 2100 et seq.). An alternative basis for the prohibition, however, is the authority 

granted the ARB to control toxic air contaminants (TACs) under Health and Safety Code 

section 39665 et seq. 

2. Proposed Mitigation Measure Related to Greenhouse Gas 

 Emissions 

Staff evaluated data for categories for which VOC limits are proposed to determine 

whether compounds with higher GWP values could be used to reformulate products. 
Technical Support Document Chapter IX - 151 

Limited use of the propellant HFC-152a was reported in several categories. Although 

not reported, staff determined that use of the exempt VOC propellant HFC-134a could 

occur. A very small amount (less than 1 pound per day) of the exempt VOC 

HCFC-141b was reported in one category. We have since learned that products 

containing this compound are no longer sold in California. 

Even though it does not appear that use of compounds with high GWPs is necessary or 

desirable, staff is proposing a mitigation measure in accordance with CEQA to ensure 

that use of compounds with higher GWP values does not begin as products are 

reformulated to meet the proposed VOC limits. Specifically a GWP limit of 150 is 

proposed for Flying Bug Insecticide, Furniture Maintenance Product, Metal Polish or 

Cleanser, Spot Remover, Special-purpose Lubricant, and Wasp or Hornet Insecticide 

products. These provisions are proposed in subsection 94509(n). 

This limit would not preclude use of HFC-152a, an exempt VOC with a moderate GWP 

of 140. The proposed limit would prohibit use of HFC-134a which has a GWP value 

of 1,300. 

Staff believes that the VOC limits for these categories are set at a level that does not 

mandate the use of compounds with GWP values of 150 or greater. Staff also 

determined that a variety of reformulation technologies exist such that use of 

compounds with higher GWPs is not necessary in these categories. More detailed 

information on alternative products and chemicals that can be used as products 

reformulate is contained in Chapter VII. 

3. Proposed Mitigation Measure Related to Use of Alkylphenol 

Ethoxylates 

Staff is also proposing to prohibit the use of certain alkylphenol ethoxylate surfactants in 

several categories as a CEQA mitigation measure. Alkylphenol ethoxylates are 

nonionic surface active agents (surfactants) used as wetting agents, emulsifiers, and 

dispersants in cleaning and degreasing products. One reformulation pathway to meet 

proposed VOC limits would be to replace VOC solvents with surfactants, such as 

alkylphenol ethoxylates. Alkylphenol ethoxylates meet the definition of LVP-VOC so 

their use is not currently restricted by the VOC limits in the Consumer Products 

Regulation. In the cleaning/degreasing categories, because of how the products are 

used, some product is washed ‘down the drain.’ Once into wastewaters, alkylphenol 

ethoxylates do not readily degrade and they and/or their degradation products enter 

aquatic environments through wastewater treatment facilities and storm water. 

Ample scientific evidence implicates the alkylphenol ethoxylates as toxic to aquatic 

species. Among other things, they are suspected hormone disruptors, with the primary 

concern focused on the estrogenic effects of their degradation products (David et al., 

2009). In particular, two alkylphenols, octylphenol and nonylphenol, have been shown 

to mimic the hormone estrogen. In light of this, staff consulted with staff of the State 
Technical Support Document Chapter IX - 152 

Water Resources Control Board (SWRCB) to determine if use or increased use of 

alkylphenol ethoxylates would pose an adverse impact on California’s receiving waters. 

Information provided to the SWRCB staff indicates that alkylphenol ethoxylates are 

found in measurable concentrations in the State’s receiving waters. Moreover, SWRCB 

staff is concerned that any potential increased use of alkylphenol ethoxylates could 

adversely impact aquatic species (SWRCB, 2010a; SWRCB, 2010b; SCCWRP, 2010; 

and SFEI, 2010). As proposed, after December 31, 2012, use of alkylphenol ethoxylate 

surfactants would be prohibited from use in General Purpose Cleaner (nonaerosol), 

General Purpose Degreaser (nonaerosol), Glass Cleaner (nonaerosol), and Oven or 

Grill Cleaner products. For Heavy-duty Hand Cleaner or Soap (nonaerosol) products 

the prohibition would become effective December 31, 2013. These prohibitions are 

proposed to ensure that use of these compounds does not occur as products are 

reformulated to meet the proposed VOC limits. This proposal would be contained in 

modified subsection 94509(m)(3). 

Staff also finds that replacements for alkylphenol ethoxylates are readily available. 

Alcohol ethoxylate, linear alkylbenzene sulphonates, and alkyl polyglucosides 

surfactants are considered to be effective and environmentally safer. 

F. Risk Assessment for Implementing the Proposed Amendments 

The health risks associated with ozone exposure have been known for many years and 

are discussed in detail in Chapter IV. Studies have shown that when inhaled, even at 

relatively low levels, ozone can impact lung tissue and lung function. The greatest risk 

is to those who are more active outdoors during smoggy periods, such as children, 

athletes, and outdoor workers. Exposure to levels of ozone above the current ambient 

air standard leads to lung inflammation and lung tissue damage, and a reduction in the 

amount of air inhaled into the lungs. 

Recent evidence has linked the onset of asthma to exposure to elevated ozone levels in 

exercising children (McConnell et al., 2002). It has also been shown that ozone 

exposure is associated with premature death. The actual lowering of health risks that 

would result from reducing VOC emissions, if the staff’s proposal were to be adopted, is 

not quantified in this report. Qualitatively, however, we are able to conclude that 

reducing VOC emissions, because of their role as ozone precursors, will result in 

incremental improvement of the public’s health because the reductions represent 

progress toward attaining both the national and State ozone standards. 

As shown in Table IX-1, the proposed amendments are designed to achieve the 

maximum feasible VOC emission reduction from the categories proposed for regulation 

at this time. When fully effective, adopting the amendments would result in a VOC 

emissions reduction of about 6.9 tons per day. Of this amount, 6.7 tons per day would 

be creditable toward the 2007 SIP while an additional 0.2 tons per day reduction would 

be credited toward a future SIP commitment. The impacts of our proposal on SOA 

formation are not clear, although we do not expect a disbenefit. 
Technical Support Document Chapter IX - 153 

Prohibition of the use of the chlorinated TAC solvents methylene chloride, 

perchloroethylene, and trichloroethylene in certain categories would reduce exposure to 

these potential human carcinogens and further protect public health. The proposed 

GWP limits are designed to ensure that the emissions of reformulated products do not 

pose a climate change impact. 

The prohibition on use of alkylphenol ethoxylate surfactants should reduce aquatic 

species’ exposure to these known hormone disruptors. 

G. Alternative Means of Compliance 

Two alternative means of compliance with the Consumer Products Regulation have 

been adopted. A current compliance alternative for manufacturers of consumer 

products is the Alternative Control Plan (ACP). The ACP Regulation, title 17, California 

Code of Regulations, sections 94540-94555, is a voluntary emissions averaging 

program. This means that a manufacturer may sell some products that exceed the 

VOC limits in the Regulation as long as those increased emissions were offset by 

additional products that overcomply with the VOC limits. The ACP provides 

manufacturers with flexibility, but preserves the overall environmental benefits of 

emission reductions. 

Another compliance alternative that is available for manufacturers is the Innovative 

Products Provision specified in title 17, California Code of Regulations, section 94511. 

This provision allows a manufacturer to formulate products that exceed a mass-based 

limit for a particular product category. The manufacturer must demonstrate that, 

through some characteristic of the higher VOC product, its use will result in less VOC 

emissions compared to a representative complying product. This alternative is also 

specifically designed to allow manufacturers flexibility, while preserving the emission 

benefits of the Regulation. 

Absent use of either of these alternatives, staff is not aware of any additional 

compliance means, other than direct compliance with the proposed amendments. More 

information is available in Chapter V of this report. 

H. Environmental Justice 

State law defines environmental justice as the fair treatment of people of all races, 

cultures, and incomes with respect to the development, adoption, implementation, and 

enforcement of environmental laws, regulations, and policies. The ARB is committed to 

evaluating community impacts of proposed regulations, including environmental justice 

concerns. 

Consumer products are considered area sources and, as such their use is not focused 

in a particular area leading to a potential “hot spot.” Generally, use of consumer 

products is fairly uniform across the State, tracking with housing units, and their 
Technical Support Document Chapter IX - 154 

emissions are spread over the course of a day, rather than concentrated at a particular 

time of day. For these reasons, we do not believe that people of any given race, 

culture, or income would be more impacted than any others would. All Californians 

should benefit equally from the reduction in VOC emissions from the consumer product 

categories proposed for regulation. 

REFERENCES 

1. Air Resources Board. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation. May 9, 2008. (ARB, 2008a) 

2. Air Resources Board. Environmental Impact Assessment of Selected 

Halogenated Chemicals – Staff Report. March, 2008. (ARB, 2008d) 

3. Air Resources Board. Initial Statement of Reasons for the Proposed 

Amendments to the California Aerosol Coating Products, Antiperspirants and 

Deodorants, and Consumer Products Regulations, Test Method 310, and 

Airborne Toxic Control Measure for para-Dichlorobenzene Solid Air Fresheners 

and Toilet/Urinal Care Products. May 7, 2004. (ARB, 2004b) 

4. Air Resources Board. Initial Statement of Reasons for the Proposed Airborne 

Toxic Control Measure for Emissions of Chlorinated Toxic Air Contaminants from 

Automotive Maintenance and Repair Activities. March 10, 2000. (ARB, 2000) 

5. Air Resources Board. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation: Midterm Measures II. 

 September 10, 1999. (ARB, 1999) 

6. Bowman, F.M., Pilinis, C. and Seinfeld, J.H. Ozone and Aerosol Productivity of 

Reactive Organics. 1994. Atmospheric Environment. Volume 29: 579-589. 

(Bowman et al., 1994) 

7. Chan, A., Kautzman, B., Surratt, J., Chhabra, P., Chan, M.N., Crounse, J., 

Wennberg, P., Flagan, R., Seinfeld, J. Understanding Secondary Organic 

Aerosol (SOA) Formation from Lower-Volatility Precursors: Photooxidation of 

Naphthalene and Alkyl-naphthalenes. February 27, 2009. (Chan et al., 2009) 

8. David, A., Fenet, H., Gomez, E. Alkylphenols in Marine Environments: 

Distribution Monitoring Strategies and Detection Considerations. 2009. Marine 

Pollution Bulletin. Volume 58: 953-960. (David et al., 2009) 

9. Finlayson-Pitts, B.J. and Pitts Jr., J.N. Chemistry of the Upper and Lower 

Atmosphere. Chapter 9, Academic Press, New York, 2000. 

 (Finlayson- Pitts and Pitts, 2000) 
Technical Support Document Chapter IX - 155 

10. Griffin, R.J., Cocker III, D.R., and Seinfeld, J.H. Incremental Aerosol Reactivity: 

Application to Aromatic and Biogenic Hydrocarbons. 1999. Environmental 

Science & Technology. Volume 33: 2403-2408. (Griffin et al., 1999) 

11. Grosjean, D. In Situ Organic Aerosol Formation during a Smog Episode: 

Estimated Production and Chemical Functionality. 1992. Atmospheric 

Environment. Volume 26A, Number 6: 953-963. (Grosjean, 1992) 

12. McConnell, R., Berhane, K., Gilliland, F., London, S.J., Islam, T., Gauderman, 

W.J., Avol, E., Margolis, H.G., Peters, J.M. Asthma in Exercising Children 

Exposed to Ozone: A Cohort Study. 2002. Lancet. Volume 359: 386-391. 

(McConnell et al., 2002) 

13. Moolgavkar, S.H. and Luebeck, E.G. A Critical Review of the Evidence on 

Particulate Air Pollution and Mortality. 1996. Epidemiology. Volume 7, Number 4: 

420-428. (Moolgavkar and Luebeck, 1996) 

14. Office of Environmental Health Hazard Assessment. Provisional Reference 

Exposure Levels (RELS) Compounds of Interest As Possible LVP-VOCS. 

Memorandum dated September 16, 2010, from Melanie Marty, Ph.D., Chief, Air 

Toxicology and Epidemiology Branch, Office of Environmental Health Hazard 

Assessment, to Janette Brooks, Chief, Air Quality Measures Branch, Air 

Resources Board. (OEHHA, 2010) 

15. Pandis, S.N., Harley, R.A., Cass, G.R., and Seinfeld, J.H. Secondary Organic 

Aerosol Formation and Transport. 1992. Atmospheric Environment. Volume 26A: 

2269-2282. (Pandis et al., 1992) 

16. Schwartz, J., Dockery, D.W., and Neas, L.M. Is Daily Mortality Associated 

Specifically with Fine Particles? 1996. Journal of the Air & Waste Management 

Association. Volume 46: 927-939. (Schwartz et al., 1996) 

17. San Francisco Estuary Institute. Occurrence of Alkylphenol Ethoxylate 

Surfactants in San Francisco Bay and Potential Impacts on Water Quality. 

Memorandum dated July 13, 2010, from Rainer Hoenicke, Ph.D., Executive 

Director, San Francisco Estuary Institute, to Darrin Polhemus, Deputy Director, 

Division of Water Quality, State Water Resources Control Board. (SFEI, 2010) 

18. Seinfeld, J.H. and Pandis, S.N. Atmospheric Chemistry and Physics-From Air 

Pollution to Climate Change. John Wiley & Sons, Inc. New York. 1998. 

 (Seinfeld and Pandis, 1998) 

 

19. Singer, B.C., Destaillats, H., Hodgson, A.T., and Nazaroff, W.W. Cleaning 

Products and Air Fresheners: Emissions and Resulting Concentrations of Glycol 

Ethers and Terpenoids. Indoor Air. 2006. Volume 16: 179-191. 

 (Singer et al., 2006) 
Technical Support Document Chapter IX - 156 

20. Southern California Coastal Water Research Project. Effects on Water Quality of

Alkylphenol Ethoxylate Surfactants (APEOs). Memorandum dated July 15, 2010, 

from Keith Maruya, Principle Scientist, Southern California Coastal Water 

Research Project, to Darrin Polhemus, Deputy Director, Division of Water 

Quality, State Water Resources Control Board. (SCCWRP, 2010) 

21. State Water Resources Control Board. Water Quality Effects of Alkylphenol 

Ethoxylate Surfactants. Memorandum dated September 20, 2010, from Darrin 

Polhemus, Deputy Director, Division of Water Quality, State Water Resources 

Control Board, to Richard Corey, Chief, Stationary Source Division, Air 

Resources Board. (SWRCB, 2010a) 

22. State Water Resources Control Board. Effects on Water Quality of Alkylphenol 

Ethoxylate Surfactants. Memorandum dated July 19, 2010, from Valerie Connor, 

Ph.D., Deputy Director, Office of Information Management and Analysis, State 

Water Resources Control Board, to Darrin Polhemus, Deputy Director, Division of 

Water Quality, State Water Resources Control Board. (SWRCB, 2010b) 

23. United States Environmental Protection Agency. Environmental Indicators: 

Ozone Depletion. July 8, 2003. http://www.epa.gov/spdpublc/science/indicat/. 

(U.S. EPA, 2003a) 
Technical Support Document Chapter X - 157 

Chapter X. Future and Ongoing Activities 

In this chapter, we describe future and ongoing activities related to the consumer 

products program. These activities are directed at developing proposals to further 

reduce volatile organic compounds (VOC), air toxic, and greenhouse gas emissions 

from consumer products. As always, our rulemaking activities will be conducted using a 

transparent process, allowing for stakeholder input. Major activities are summarized 

below. 

A. Consumer Product Emissions Reduction Commitments in the 

State Implementation Plan (SIP)

As described in Chapter III, in the 2007 SIP, the State Strategy for California’s 2007 

State Implementation Plan, ARB committed to achieving a further 30 to 40 tons per day 

statewide VOC emission reduction from consumer products by 2014. The amendments 

proposed in this rulemaking represent the third increment toward achieving the 

commitment. Table X-1 shows our progress toward meeting the consumer products 

commitment in the SIP. 

Table X-1 

Consumer Product VOC Reductions Accredited Toward SIP Commitment

Consumer Products Rulemaking Statewide VOC Reductions (tons per day) 

June 2008 Amendments 4.5 (adopted) 

September 2009 Amendments 14.7* (adopted) 

2010 Amendments 

(this proposal) 6.7 (proposed) 

Additional Reductions from 

Consumer Product Categories ~ 4.0 – 14.0 

Totals Reductions by January 1, 2014 30 – 40 

* Emission reductions of about 12.7 tons per day of this reduction occur in all areas of the State 

 except the South Coast Air Quality Management District (district has their own rule, Rule 1143, 

 for Paint Thinners and Multi-purpose Solvents) (ARB, 2009c). 

As shown in Table X-1, adopted amendments will result in 19.2 tons per day toward the 

commitment. If adopted the amendments proposed here would provide an additional 

6.7 tons per day statewide toward the commitment. The remaining commitment would 

be to achieve at a minimum about 4.0 tons per day by the end of 2013. Proposed 

amendments to complete the emission reduction commitment will occur in 2011. 
Technical Support Document Chapter X - 158 

Earlier this year U.S. EPA began reconsidering the “primary” ozone standard of 

0.075 ppm. To be more health protective U.S. EPA proposed a revised standard in the 

range of 0.060 to 0.070 ppm (U.S. EPA, 2010c). The final rule is expected in October of 

this year (2010). The revision will require that a new SIP be drafted in the 2013 

timeframe. This SIP will likely require more VOC reductions from consumer products. 

B. Consumer and Commercial Products Survey 

A survey of various categories of consumer products will be conducted to obtain the 

necessary data to propose limits to meet the final increment of emission reductions in 

the 2007 SIP. Among the categories to be included are aerosol coatings, aerosol 

adhesives, Deodorant Body Sprays, Antiperspirants, Deodorants, Undercoatings 

(aerosol), hair care products, and sun tanning/block products. 

C. Compliance Assistance 

Compliance assistance activities in 2011 will include exploring options for identifying 

complying products destined for sale in California and developing advisories. 

Advisories will be developed to address questions that have been raised related to 

provisions in section 94509(b). This subsection specifies how VOC content is 

determined for concentrated products, but provides an exclusion for “incidental use” of a 

more concentrated product. The goal of the advisory would be to clarify what 

constitutes “incidental use.” Additional advisories will be explored to clarify how VOC 

limits for “general” or “multi-purpose” products are enforced. 

REFERENCES 

1. Air Resources Board. Initial Statement of Reasons, Proposed Amendments to 

the California Consumer Products Regulation. August 7, 2009. (ARB, 2009c) 

2. United States Environmental Protection Agency. National Ambient Air Quality 

Standards for Ozone (40CFR Parts 50 and 58). Federal Register: 

 January 19, 2010. Volume 75, Number 11. (U.S. EPA, 2010c)