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. o r g October 16 , 2012

Air Resources Board
1001 I Street, 23 rd Floor Sacramento, California 95814

Attn: Ms. Lori Andreoni Manager, Board Administration and Regulations Coordination Unit http:// www.arb.ca.gov/lispub/comm/bclist.php

Subject: Proposed Amendments to the California Consumer Products Regulation Pertaining to Automotive Windshield Washer Fluid Products; Board Agenda Item # 12

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Dear Board Members:

The Automotive Specialty Product s Alliance (ASPA) appreciates the opportunity to offer comments on the California Air Resources Board (ARB) proposal to modify current regulatory requirements for Automotive Windshield Washer Fluid (AWWF) Products. As discussed below, ASPA supports the

ARB proposal to r edefine “Type A ” a reas to be tter characterize areas of the s tate that generally experience freezing temperatures , and to clarify the definition of the AWWF product category

.

1. The modified definition of the AWWF product category in ARB’s propo sal improves the clarity of the applicable requirements.

ASPA strongly supports ARB’s proposal to consolidate all definitions pertaining to the AWWF category in a single modified definition. Clearly defined product categories and related terms are

critica lly important to California’s complex and comprehensive Consumer Products Regulation [17 CCR §94508 (a)].

The current description of Type “A” area lists: (1) specific air basins that are defined in other sections of the California Code of Regulations, or (2) entire counties. 1 The current reference to specified air basins

is not readily comprehensible. Therefore, A SPA supports ARB’s proposal to include the names of the counties that comprise the air basins in the Type “A” area. A SPA agrees with ARB staff’s statement that “...county boundaries are more readily understood than are air basins boundaries.” 2

A SPA also supports ARB’s proposal to use the U.S. Postal Service’s zip codes to identify the freezing regions of the s tate that are being added to the Type “A” area. A SPA agrees with ARB staff’s conclusion that zip codes “...are commonly used and understood...and their use would provide a practical way for manufacturers, distributors, and retailers to manage the distribution and sale of AWWF products into the new Type ‘A’ areas.” 3

1 See Table of Sta ndards at 17 CCR § 94509(a).

2 ARB, “Staff Report: Initial Statement of Reasons, Proposed Amendments to the California Regulation for
Reducing Emissions from Consumer Products Pertaining to Automotive Windshield Washer Fluid Produc ts,” (Aug. 29,
2012) at Ch. 2 p . 16.

3 Id. at Ch. 2 p. 11.ASPA Comments on Board Agenda Item # 12

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October 16 , 2012 Page 2 of 2

2. ARB’s proposed modification s will promote public safety by including additional parts of the state, which routinely experience free zing temperatures, in the “Type A” a rea.

The use of freeze

- resistant pre

- mixed ( i.e. ready

- to

- use) AWWF produ cts enables drivers to maintain clear vision during the winter months, when drivers in colder areas of the state must routinely contend with ice, snow, freezing rain and road spray on their windshields. Expanding the “ Type A” a rea to include narrowly

- defi ned additional parts of the state (identified by zip codes) that routinely experience freezing, ARB will ensure drivers will be able to use freeze

- resistant AWWF products to maintain the clear vision necessary to safely operate their vehicles in freezing c onditions

– a boon to public safety.

3. ARB’s proposed modification to labeling requirements for concentrated AWWF products will improve safety for drivers who travel to areas of the state that experience freezing temperatures.

The draft proposed modifications will permit product labels for dilutable ( i.e. concentrated ) AWWF products to include instructions informing consumers that they may follow the dilution instructions for “Type A’ a reas when travelling to areas in California with freezing temperatures. ASPA supports this proposed revision since it will allow manufa cturers to provide instructions on product labels that clearly communicate that drivers may legally mix dilutable AWWF to prevent it from freezing in the vehicles

windshield washer fluid reservoir.

If you have any questions, please contact me at 202

- 833

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About ASPA: The Automotive Specialty Products Alliance c ombines the efforts of the Automotive Aftermarket Industry Association (AAIA), the Consumer Specialty Products Association (CSPA), and the Motor & Equipment Manufacturers Association (MEMA)

– t hree national trade associations representing companies engaged in the manufacture, formulation, distribution, and sale of automotive specialty products . ASPA presents a unified industry voice for the associations’ members engaged in the

automotive chemic al and vehicle appearance products markets

.

Respectfully submitted,

Sean R. Moore On behalf of the ASPA Operating Committee and Board of Directors



### cc: Carla D. Takemoto, Chief, Area Source and Emissions Inventory Programs Branch, PTSD
Jose Gomez, Ma nager, Technical Development Section, Area Source and Emissions Inventory Programs Branch, PTSD Olufemi Olaluwoye, Air Pollution Specialist, Technical Development Section, Area Source and Emissions Inventory Programs Branch, PTSD