Comment 1 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Anne

Last Name: Meininger

Email Address: anne.meininger@nist.gov

Phone Number: 301-975-2921

Affiliation: NIST/US Dept of Commerce

Subject: ASTM comments on use of ASTM standards in the CA consumer products regulations

Comment:

Hello California,


This office at the National Institute of Standards and Technology

is the USA WTO Technical Barriers to Trade Inquiry Point. We

notifed WTO of the CA consumer regulations and received the

attached comments from a US interest, ASTM International.


Please acknowledge receipt of the attached comments if that is

possible.


Thank you,


Anne Meininger


USA WTO TBT Inquiry Point


National Center for Standards and Certification Information


National Institute of Standards and Technology


100 Bureau Drive, MS-2100


Gaithersburg, MD 20899-2100


Telephone: 301-975-4040 or 301-975-2921


Fax: 301-926-1559


Email: ncsci@nist.gov or anne.meininger@nist.gov


Attachment: www.arb.ca.gov/lists/cp2008/2-astm_comments_on_usa393.doc

Original File Name: ASTM_comments_on_USA393.doc 

Date and Time Comment Was Submitted: 2008-06-03 09:44:11

No Duplicates.
Comment 2 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Adriana

Last Name: Franco

Email Address: christina@coalitionforcleanair.org

Phone Number: 

Affiliation: 

Subject: Strengthen The Consumer Products Regulation

Comment:

Mary Nichols


Chairman


California Air Resources Board


1001 “I” Street


P.O. Box 2815 


Sacramento, CA 95812


Dear Chairman Nichols,


I encourage you to strongly reduce the harmful toxics found in

cleaning and other consumer products. By regulating and reducing

these chemicals from consumer products, the State of California

will set another precedent in protecting the health of families

and workers. 


Volatile organic compounds (VOCs), harm our families’ health and

contaminate our air. Everyone is vulnerable to the harmful

effects of these chemicals, which are often used where we work and

live and where our children study and play. 


Many children in our communities suffer from asthma, and the

chemicals emitted by consumer products only increase the chances

that they endure more frequent attacks or develop asthma in the

future. Furthermore, adults may experience an increased risk of

liver and kidney damage and cancer from the daily use of consumer

products. 


As a consumer and concerned citizen, I urge the California Air

Resources Board to adopt tougher regulations on consumer products.

I also urge you to include additional VOC reductions from some of

the worst culprits – multipurpose cleaners, degreasers and glass

cleaners.


Please take this opportunity to protect the health of our families

by significantly reducing these air pollutants that emanate from

consumer products. 


Thank you.


Attachment: www.arb.ca.gov/lists/cp2008/3-comments_adriana_franco.jpg
Original File Name: Comments_Adriana_Franco.jpg 

Date and Time Comment Was Submitted: 2008-06-10 13:51:52

125 Duplicates.
Comment 3 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Ruby

Last Name: Ghadially

Email Address: Non-web submitted comment

Phone Number: 

Affiliation: 

Subject: Re; Consumer Product Rulemaking; Astrigents/ Toners

Comment:

Please see attached. 

Attachment: www.arb.ca.gov/lists/cp2008/118-cp080001.pdf

Original File Name: cp080001.pdf 

Date and Time Comment Was Submitted: 2008-06-18 10:33:30

No Duplicates.
Comment 4 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Robin

Last Name: Gentz

Email Address: robin.gentz@clorox.com

Phone Number: 

Affiliation: The Clorox Company

Subject: Board Agenda Item #08-6-5

Comment:

Please see attached letter.

Attachment: www.arb.ca.gov/lists/cp2008/119-2008_cmts_to_arb.pdf

Original File Name: 2008 Cmts to ARB.pdf 

Date and Time Comment Was Submitted: 2008-06-19 13:53:50

No Duplicates.
Comment 5 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Larry

Last Name: Beaver

Email Address: lbeaver@gunk.com

Phone Number: 704-684-1802

Affiliation: Radiator Specialty Company

Subject: Comments regarding Consumer Products VOC regulation changes

Comment:

Radiator Specialty Company produces products for the Car Care

Industry. Many of our customers are DIY and commercial

establishments that service automobiles. 


Radiator Specialty Company appreciates the opportunity to comment

on this regulation. We support the limits and effective dates for

the Multi-purpose Lubricants and Penetrants category. These are

technology-forcing limits.


Radiator Specialty also supports the provision to allow the

continued manufacturer of penetrants that are non-flammable. 

Penetrants can be used in situations were energized circuits, high

heat sources, or open flames exist. Non-flammable products are

needed to ensure safety to the consumer in these situations.


Thank you for your consideration on this issue. Any questions or

comments feel free to contact me at 704-684-1802 or by e-mail at

lbeaver@gunk.com. 


Respectfully submitted,


Larry Beaver


Vice President, Technology


Attachment: www.arb.ca.gov/lists/cp2008/121-radspeccommentstoarb62508.doc

Original File Name: RadSpecCommentstoARB62508.doc 

Date and Time Comment Was Submitted: 2008-06-23 10:17:29

No Duplicates.
Comment 6 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: D. Douglas

Last Name: Fratz

Email Address: dfratz@cspa.org

Phone Number: 202-833-7304

Affiliation: Consumer Specialty Products Association

Subject: CSPA Comments on Board Agenda Item #08-6-5

Comment:

See comments attached.

Attachment: www.arb.ca.gov/lists/cp2008/122-

cspa_comments_on_arb_proposed_2008_amemdments_6-23-08.pdf

Original File Name: CSPA Comments on ARB Proposed 2008 Amemdments 6-23-08.pdf 

Date and Time Comment Was Submitted: 2008-06-23 11:25:31

No Duplicates.
Comment 7 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Paul

Last Name: Gardner

Email Address: pgardner@blasterchemical.com

Phone Number: 

Affiliation: 

Subject: Consumer Products rule

Comment:

See attachment

Attachment: www.arb.ca.gov/lists/cp2008/129-high_performance_creative_chemistry.doc

Original File Name: HIGH PERFORMANCE CREATIVE CHEMISTRY.doc 

Date and Time Comment Was Submitted: 2008-06-23 12:58:19

No Duplicates.
Comment 8 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Gary

Last Name: Silvers

Email Address: gsilvers@meguiars.com

Phone Number: 949-752-3821

Affiliation: Meguiar's, Inc.

Subject: Proprosed Amendments to Ca. Consumer Products Reguations 6/25/08; Board Agenda

Item#08-6-5

Comment:

June 23, 2008


Board Members


Air Resources Board


1001 I Street, 23rd Floor 


Sacramento, California 95814


Attn: Ms. Lori Andreoni, Board Secretary


http://www.arb.ca.gov/lispub/comm/bclist.php


Subject:	Proposed Amendments to the California Consumer Products

Regulations 6/25/08; Board Agenda Item # 08-6-5


Dear Board Members: 


 


Meguiar’s is a manufacturer of premier car care products. Our

products are distributed through numerous retail outlets. What

began a century ago as a simple furniture polish laboratory and

plant now spans four generations of Meguiar family stewardship.

Celebrating its 100th anniversary in 2001, Meguiar's, Inc. has

become one of the world's leading surface care products companies,

providing highly specialized products for almost every conceivable

type of surface.


Meguiar’s appreciates the opportunity to comment on this rule. 

Our sole comment is that the current definition of “motor vehicle

wash” will ban our aerosol form of the product. The majority of

the products in this category are dilutable products. After

closer review of the proposed wording we realized one of our niche

products would be banned. The aerosol product Quick Mist label is

attached. This product was introduced after 2003 thus not subject

to the 2003 survey.


Meguiar’s respectfully requests the ARB to modify the existing

wording of the definition to remove aerosol products from this

category.


Thank you for in advance for your attention to this issue. If

there are any questions or comments please feel free to contact me

at (949) 752-3821.


	


Respectfully submitted

Attachment: www.arb.ca.gov/lists/cp2008/136-a3318_quikdetaileraero1.pdf

Original File Name: A3318_QuikDetailerAero1.pdf 

Date and Time Comment Was Submitted: 2008-06-23 15:46:46

No Duplicates.
Comment 9 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Jerry

Last Name: Ulrich

Email Address: julrich@fourstarchemical.com

Phone Number: 

Affiliation: 

Subject: Consumer Products regulation

Comment:

See attachment

Attachment: www.arb.ca.gov/lists/cp2008/137-4-star-carb_6-25-08__2_.pdf

Original File Name: 4-star-carb 6-25-08 (2).pdf 

Date and Time Comment Was Submitted: 2008-06-24 07:45:46

No Duplicates.
Comment 10 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Steve

Last Name: Cook

Email Address: scook@techspray.com

Phone Number: 800-858-4043

Affiliation: 

Subject: consumer products regulation

Comment:

see attachment

Attachment: www.arb.ca.gov/lists/cp2008/138-carb_board_agena_item___08-06-5.doc

Original File Name: carb board agena item # 08-06-5.doc 

Date and Time Comment Was Submitted: 2008-06-24 08:00:48

No Duplicates.
Comment 11 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Sharon H.

Last Name: Kneiss

Email Address: sandra_andrade@americanchemistry.com

Phone Number: 703-741-5617

Affiliation: American Chemistry Council SIG

Subject: Comments on the CARB Proposed Amendments to the Regulation for Reducing VOC

Emissions 

Comment:

Comments on the CARB Proposed Amendments to the Regulation for

Reducing VOC Emissions from Consumer Products submitted by the ACC

Solvents Industry Group.

Attachment: www.arb.ca.gov/lists/cp2008/139-final_carb_comments_on_voc_062408.pdf

Original File Name: FINAL CARB Comments on VOC 062408.pdf 

Date and Time Comment Was Submitted: 2008-06-24 08:36:24

No Duplicates.
Comment 12 for Consumer Products Regulations (cp2008) - 45 Day.

This comment was posted then deleted because it was unrelated to the Board item or it was a

duplicate.
Comment 13 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Ray

Last Name: Cull

Email Address: ray.cull@us.henkel.com

Phone Number: 440 937 7457

Affiliation: Henkel Consumer and Pro Div

Subject: Comments on Sealants & caulks

Comment:

See attached letter

Attachment: www.arb.ca.gov/lists/cp2008/141-sealant_response_letter_june_24.doc

Original File Name: sealant response letter June 24.doc 

Date and Time Comment Was Submitted: 2008-06-24 11:37:27

No Duplicates.
Comment 14 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Valerie

Last Name: Ramsey

Email Address: Ramseyv@cbfleet.com

Phone Number: 

Affiliation: 

Subject: Proposed Amendments to the CA Consumer Product Regulations 6/25/08; Agenda Item

#08-6-5

Comment:

Comments attached.

Attachment: www.arb.ca.gov/lists/cp2008/142-carb_comments.pdf

Original File Name: CARB Comments.pdf 

Date and Time Comment Was Submitted: 2008-06-24 12:53:10

No Duplicates.
Comment 15 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: John 

Last Name: Davis

Email Address: jdavis@plaze.com

Phone Number: 5732593423

Affiliation: Plaze, Inc./Claire Sprayway

Subject: June 25th Board Hearing Comments

Comment:

Comments for June 25th Board Hearing. 


Attachment: www.arb.ca.gov/lists/cp2008/145-air_resources_board.pdf

Original File Name: Air Resources Board.pdf 

Date and Time Comment Was Submitted: 2008-06-24 14:21:33

No Duplicates.
Comment 16 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Ruby

Last Name: Ghadially

Email Address: Non-web submitted comment

Phone Number: 

Affiliation: 

Subject: Re: Consumer Product Rulemaking ; Astrigents/ Toners

Comment:

Please see attached. 

Attachment: www.arb.ca.gov/lists/cp2008/146-ghadially_letter_062408.pdf

Original File Name: Ghadially letter 062408.pdf 

Date and Time Comment Was Submitted: 2008-06-24 16:07:42

No Duplicates.
Comment 17 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Harry

Last Name: Zechman

Email Address: hzechman@stonersolutions.com

Phone Number: 

Affiliation: 

Subject: Consumer Products Regulation

Comment:

See attachment

Attachment: www.arb.ca.gov/lists/cp2008/147-

stoner_comments_arb_june_25_2008_proposal__4_.doc

Original File Name: Stoner Comments ARB June 25 2008 proposal (4).doc 

Date and Time Comment Was Submitted: 2008-06-24 16:29:01

No Duplicates.
Comment 18 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: William

Last Name: Burke

Email Address: Non-web submitted comment

Phone Number: 

Affiliation: 

Subject: South Coast Air Quality Management District

Comment:

Please see attached. 

Attachment: www.arb.ca.gov/lists/cp2008/149-scan0001.pdf

Original File Name: scan0001.pdf 

Date and Time Comment Was Submitted: 2008-06-24 16:45:45

No Duplicates.
Comment 19 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Philip

Last Name: Lapin

Email Address: plapin@falconsafety.com

Phone Number: 9087074900x272

Affiliation: Falcon Safety Products

Subject: Proposed Amendments to the California Consumer Products Regulations 

Comment:

June 25, 2008


Honorable Board Members


Air Resources Board


1001 I Street, 23rd Floor


Sacramento, California 95814


Dear Honorable Board Members:


I am writing in support of the proposed amendment to the

Regulation for Reducing Emissions from Consumer Products. More

specifically, we are in support of the new requirements for

Pressurized Gas Dusters to contain a propellant compound that has

a Global Warming Potential (GWP) value of 150 or less. As the

leading manufacturer of compressed gas dusters, Falcon Safety

Products has been aggressively promoting the use of HFC 152a as

its primary choice propellant in dusters for the last 15 years.

Our company chose this strategy because we believe strongly in the

environmental benefit, and efficacy of this lower GWP compound.

Because of our company’s action, there has been an overall trend

in the duster industry towards using HFC 152a in duster products. 

We would like to commend the staff of the Air Resources Board for

working judiciously towards finding the appropriate path forward

for our industry in California. And until there is a future

generation of compounds, we believe that HFC152a is a safe,

effective and necessary compound for use in aerosol applications.


Thank you for your consideration.


Sincerely,


Philip M. Lapin


President/CEO


Falcon Safety Products


Attachment: 

Original File Name: 
Date and Time Comment Was Submitted: 2008-06-25 06:16:24

No Duplicates.
Comment 20 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Daniel

Last Name: Pourreau

Email Address: dan.pourreau@lyondellbasell.com

Phone Number: 610-359-2411

Affiliation: 

Subject: Comments on Proposed Amendments to Consumer Products Rule

Comment:

Please find our comments in the attached .zip file.


Please confirm receipt of our comments and call me if you have

problems opening or viewing the letter in pdf format.


Thanks,


Dan Pourreau


LyondellBasell Industries.

Attachment: www.arb.ca.gov/lists/cp2008/151-lyondellbasell_comments.zip

Original File Name: LyondellBasell comments.zip 

Date and Time Comment Was Submitted: 2008-06-25 07:31:13

No Duplicates.
Comment 21 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Kathleen

Last Name: Stanton

Email Address: kstanton@sdahq.org

Phone Number: 

Affiliation: 

Subject: SDA comments on Proposed Consumer Products Regulations

Comment:

Please see attached comments.

Attachment: www.arb.ca.gov/lists/cp2008/152-

sda_comments_on_arb_proposal_2008_june_20.pdf

Original File Name: SDA comments on ARB proposal 2008 June 20.pdf 

Date and Time Comment Was Submitted: 2008-06-25 09:16:00

No Duplicates.
Comment 22 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Darlene 

Last Name: Coe

Email Address: darcoe@velotech.net

Phone Number: 

Affiliation: 

Subject: Consumer Products Regulation on Sealants

Comment:

In the past construction companies I currently work with were able

to use a sealant containing a petroleum solvent. This sealant

allows them to complete their outdoor work in all 12 months of the

year, whether wet or dry or damp.


Now, we are told that we can't buy this type of sealant. That

California has outlawed them. Why? We all need to work in the

winter. Rubber sealants with a petroleum solvent are the best all

season sealants for outdoor work.


We are told you are the authority to change the rule to allow

contractors to use rubber sealants containing petroleum solvents. 

Please help us. We all want to be proud of our work and cannot

affort to have call backs due to failures. Please allow

professional contractors to use these type of sealants.

Attachment: 

Original File Name: 

Date and Time Comment Was Submitted: 2008-06-25 11:09:55

No Duplicates.
Comment 23 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: emily

Last Name: winchester

Email Address: ejworking@aol.com

Phone Number: 

Affiliation: JRW Ent. Inc.

Subject: Sealants

Comment:

My company is a construction company in the bay area. In the past

we were able to use a sealant containing a petroleum solvent. 

This sealant allowed us to complete any outdoor work in all 12

months of the year with no call backs. Now I' m told we will be

unable to purchase this product-we need to be able to work the

year around and also not keep going back and trying to correct a

leak problem. We have been told that you have the authority to

allow construction contractors to use rubber sealants containing

petroleum solvents. Please consider.

Attachment: 

Original File Name: 

Date and Time Comment Was Submitted: 2008-06-25 11:19:18

No Duplicates.
Comment 24 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Luis 

Last Name: Cabrales

Email Address: luis@coalitionforcleanair.org

Phone Number: 

Affiliation: 

Subject: 2008 Consumer Products Regulation Amendments

Comment:

COALITION FOR CLEAN AIR * COMMONWEAL *


LONG BEACH ALLIANCE FOR CHILDREN WITH ASTHMA * COALITION FOR A

SAFE ENVIRONMENT * 


HEALTHY CHILDREN ORGANIZING PROJECT * REGIONAL ASTHMA MANAGEMENT

AND PREVENTION (RAMP) INITIATIVE * SIERRA CLUB CALIFORNIA *

WOMEN'S VOICES FOR THE EARTH *


NATURAL RESOURCES DEFENSE COUNCIL *


ENVIRONMENT CALIFORNIA * CLEAN WATER ACTION *


BAY AREA HEALTHY 880 COMMUNITIES-SL *


CENTER FOR PUBLIC ENVIRONMENTAL OVERSIGHT * NATIONAL TOXIC

ENCEPHALOPATHY FOUNDATION * WORKSAFE, INC. * INSTITUTE FOR

CHILDREN'S ENVIRONMENTAL HEALTH * CONSEJO DE FEDERACIONES

MEXICANAS EN NORTEAMÉRICA * CALIFORNIA RURAL LEGAL ASSISTANCE

FOUNDATION * BOYLE HEIGHTS RESIDENT HOMEOWNERS ASSOCIATION *

RESIDENTS OF PICO RIVERA FOR ENVIRONMENTAL JUSTICE * 


SOUTHERN CALIFORNIA COALITION FOR OCCUPATIONAL SAFETY & HEALTH * 


PHYSICIANS FOR SOCIAL RESPONSIBILITY-LOS ANGELES * GREEN SCHOOLS

INITIATIVE * 


CLEAN AIR NOW * PLANNING AND CONSERVATION LEAGUE * GREENACTION FOR

HEALTH AND ENVIRONMENTAL JUSTICE * 


MERCED/MARIPOSA COUNTY ASTHMA COALITION * COMITE CIVICO DEL VALLE

* 


SOUTHERN CALIFORNIA WATERSHEDALLIANCE * 


URBAN SEMILLAS * ASIAN HEALTH SERVICES * LABOR/COMMUNITY STRATEGY

CENTER


June 25, 2008


Mary Nichols


Chairman


California Air Resources Board


1001 “I” Street


P.O. Box 2815 


Sacramento, CA 95812

Via e-mail


Re:	2008 Consumer Products Regulation Amendments


Dear Chairman Nichols:


We the cosigners are writing to comment on the revised proposal

for categories to be considered in the 2008 Consumer Products

Regulation Amendments. We applaud CARB’s efforts to reduce

emissions of volatile organic compounds (VOCs) in consumer

products. However, we encourage you to direct staff to protect the

health of California residents, consumers and workers. 


According to your staff’s own estimates, after SIP measures are

implemented, 2010 VOC emissions from consumer products will be

approximately 220 to 235 tons per day (tpd ). Additionally,

consumer products will be the second largest source category of

VOC emissions in 2010 (tied with trucks and buses), and in 2020

these products will be the leading source of VOC emissions.

Unfortunately, the current version of the Consumer Products

Regulation will reduce VOCs by just 1.7 tpd in 2010, less than one

percent of total expected emissions. Yielding to industry demands,

staff has suggested numerous delays in deadlines associated with

emission reductions for different consumer product categories,

such that full benefits associated with the 2008 proposal will not

be achieved until 2015.


We would like to start by highlighting staff’s improvements on

this proposal and commend them for their foresight in addressing

the following issues:


 REDEFINITION OF DILUTABLE PRODUCTS 


We are very pleased that staff included language redefining

dilatable products (pg. ES-13) in spray bottles. Dilutable

products bottled in containers that appear to be for immediate use

should be required to reduce their VOC limits. 


We want to use this opportunity to encourage CARB to also pay

attention to other products designed to be diluted. It is very

important that we assume that not all consumers follow diluting

instructions to the letter. Therefore, in an effort to continue

identifying emissions reductions alternatives, CARB should account

for the potential emissions of other consumer products that should

be diluted.


GLOBAL WARMING EMISSIONS FROM CONSUMER PRODUCTS


We are very supportive of staff’s efforts to start looking at

global warming emissions from consumer products. Many consumer

products and their ingredients contribute directly and indirectly

to the GHG emissions. We want to encourage this agency to think

about the possibility of addressing those products and or their

ingredients and make California the first State that officially

takes steps to reduce our Global Warming foot print.


The following is a list of concerns, which we discuss in detail

bellow, we have identified on the most recent draft staff
proposal, released May 9, 2008: 


JANITORIAL PRODUCTS


PAINT AND LACQUER THINNER AND MULTIPURPOSE SOLVENT 


PROHIBITION OF TOXICS FROM SPECIFIC CATEGORIES


•	DRY-CLEANING “SPOT REMOVERS”


•	PAINT STRIPPER METHYLENE CHLORIDE


INCREASED VOC LIMITS AND COMPLIANCE DATES FOR SEVERAL CATEGORIES


•	ODOR REMOVER (LIQUID/NON-AEROSOL)


•	ASTRINGENT/TONER


•	FABRIC SOFTENER-SINGLE USE DRYER PRODUCT


•	GLASS CLEANERS (AEROSOL FORM)


•	MULTI-PURPOSE LUBRICANTS


•	PENETRANT


•	PERSONAL FRAGRANCE NON-CHEMICALLY CURING SEALANT


CATEGORIES DELETED FROM THE DRAFT LANGUAGE


•	LIQUID AIR FRESHENERS


•	POST-SHAVE PRODUCTS


The first three categories we list in this letter will help CARB

more than triple the calculated emissions reductions expected by

staff from ALL the categories in their proposal. 


We encourage you to review this list and adopt our suggestions.


JANITORIAL PRODUCTS (Not in current draft)


The SCAQMD has joined us in this request that you direct staff to

include janitorial cleaning products in the regulation draft staff

will prepare for a vote in November. Staff has mentioned they are

in the process of compiling data from previous surveys about

possible VOC limits in cleaning products; we want this Board to

encourage staff to look at the data available and to work closely

with SCAQMD staff and advocates when setting VOC limits on

cleaning products.


SCAQMD has been researching possible VOC reductions in a broad

category of janitorial cleaning products. SCAQMD tested 21

"environmentally preferable" cleaning products from six different

manufacturers. Of the 21 products tested, 12 were General Purpose

Cleaners, General Purpose Degreasers and/or Glass Cleaners, and

all met the VOC content standard. To date, 17 products have been

certified under SCAQMD’s Voluntary Clean Air Choices Cleaner

Certification Program. When calculating the VOC content, no

exemptions were made for fragrance or low vapor pressure (LVP)

solvents. 


SCAQMD staff calculates the state would achieve a reduction of 4.5

tons per day of VOC emissions if CARB agreed to set VOC content of

institutional and industrial janitorial products to one percent by

weight (10 g/l). 


CARB staff has indicated that it is likely that several categories

originally delayed for the November hearing will not be ready to be

included in draft after all. If this is the case, we ask that you

to direct staff to gather data and prepare language to regulate

VOC emissions, toxics and other environmentally "unfriendly"

ingredients from cleaning products. If adopted, these reductions

will further benefit water quality, workers’ safety and consumers’

health. In addition, the extra emissions reductions will help

out-of-compliance districts to fill in the void left by the 2007

SIP “Black Box.”

PAINT AND LACQUER THINNER AND MULTIPURPOSE SOLVENT (Categories

delayed for future consideration)


CARB staff had informed us it was going to coordinate a work group

to discuss ideas to implement reductions from this category.

However, staff has now indicated it is unlikely this process will

take place soon enough to ensure this category is included in the

November hearing. We ask CARB to commit to setting a

health-focused emissions limit from those products and set a

timeline to regulate this category.


A VOC limit of 3% for these products will result in a huge

emissions reduction of 13.85 tpd; more than two times the

emissions reduction expected by staff from the current proposal. 

The Institute for Research and Technical Assistance (IRTA)

conducted a project sponsored by Cal/EPA's Department of Toxic

Substances Control. This project involved working with wood

furniture refinishers, auto body shops, architectural contractors

and various manufacturers of metal parts. Low-VOC safer

alternatives were tested for cleaning up coating application

equipment like spray guns, brushes and rollers and for thinning

the coatings. Alternatives that performed well and were

cost-effective included acetone, water-based cleaners and

soy-based cleaners . 


Furthermore, SCAQMD’s Rule 1171 established a 2.5% VOC requirement

for cleaning solvents in many applications, including general

cleaning during manufacturing, maintenance and repair cleaning,

and coating equipment clean-up. Every related industry has met

this regulation in the South Coast Air Basin. Unfortunately,

hobbyists and home-based businesses do not have to comply with

SCAQMD’s rule because they have access to high VOC-emitting

products at their neighborhood superstores. 


We urge CARB to ensure the Paint and Lacquer Thinners work group

takes into account IRTA’s research, which has been backed by

SCAQMD and that the category is included in the November 2008

board meeting agenda. Additionally, CARB staff should work

closely with the SCAQMD to create and implement statewide health

protective standards with a limit of 3% or lower for Paint and

Lacquer Thinner and Multipurpose Solvent, which are already in use

in Southern California. 


PROHIBITION OF TOXICS FROM SPECIFIC CATEGORIES


We are pleased that staff included language for the regulation of

toxics in specific categories, the proposal asks for a prohibition

 of methylene chloride, perchloroethylene, and trichloroethylene in

Carpet/Upholstery Cleaner,” “Fabric Protectant,” “Multi-purpose

Lubricant,” “Penetrants,” “Sealant or Caulking Compound,” and

“Spot Removers.” We support staff’s decision to prohibit those

toxics.


•	DRY-CLEANING “SPOT REMOVERS”:


 It is very unfortunate, however, that the language staff drafted

does not address “Spot Removers” used in dry-cleaners. In January

2007, CARB approved a regulation to ban PERC dry cleaners. CARB
staff informed us that they are considering removing the

exemptions that prevent them from regulating spot removers used at

dry cleaning facilities. However, this category is not yet on the

draft and staff has not indicated if the category will be included

in the November board hearing.


According to Dr. Katy Wolf, IRTA director, there are a number of

cleaners—including those dry cleaning businesses that have adopted

safer alternatives—that use trichloroethylene (TCE) and PERC

spotting chemicals. These chemicals are carcinogens and TCE, the

most commonly used, is a VOC. 


IRTA conducted a project sponsored by Cal/EPA's Department of

Toxic Substances Control and US EPA to identify, develop, test and

demonstrate alternative spotting agents for the dry cleaning

industry. This project involved working with seven textile

cleaning facilities that have adopted alternatives to PERC in dry

cleaning. IRTA identified safer, water-based and soy-based

alternatives that performed as well as the TCE and PERC

alternatives currently used by dry cleaners. The cost analysis

indicates that the alternatives are less costly than the spotting

agents used today .


We ask that CARB accelerate the process to remove the exemptions

that prevent them from regulating spot removers so they can be

regulated during the November rulemaking processes.


•	PAINT STRIPPER METHYLENE CHLORIDE:


Despite our requests, staff did not include language for a

prohibition of methylene chloride (METH or MECL) in Paint

Strippers. 


According to CARB’s own survey, annual reporting of METH tonnage

in Paint Strippers for 2006 was about 1.9 tpd. A known carcinogen,

METH is not a VOC and, thus, the challenge is finding alternatives

to this chemical that are not VOCs. 


DTSC contracted with IRTA to identify, test, develop and

demonstrate alternative non-METH stripping formulations in

consumer product applications. The aim of the project was to find

safer alternative non-METH strippers that minimized the increase

in VOC emissions. 


The project involved testing alternative non-METH stripping

formulations in four sectors including:


•	Large furniture stripping companies that use equipment to apply

stripper; 


•	Small furniture stripping companies that apply stripper by hand;

•	Contract stripping companies that strip on-site and apply

stripper by hand; and 


•	Consumer stripping where consumers apply the stripper by hand. 


This research found effective alternatives that will be classified

as Low Vapor Pressure (LVP) materials, which CARB classifies as

non-VOC emitting materials . 


We want to encourage CARB to ban METH as a toxic and set a low VOC

limit.


INCREASED VOC LIMITS AND COMPLIANCE DATES FOR SEVERAL CATEGORIES


We are very disappointed that staff increased VOC limits and

compliance dates for several categories, most of which we believe
could comply with more health-focused limits and shorter

deadlines. During the development of this regulation, our

preliminary conversations with staff indicated it would establish

more health-focused limits and shorter deadlines for the following

categories. 


 


•	ODOR REMOVER (LIQUID/NON-AEROSOL): VOC limits increased from

0.1% to 6% for non-aerosol, and 25% for aerosol; compliance dates

increased from 2012 to 2013.


In addition to increasing the VOC limits and compliance dates for

this category, CARB staff does not want to disclose the total

amount of 2008 VOC emissions created by ALL the aerosol odor

removers/eliminators in the market arguing possible damage

“confidentiality”. It is important that CARB staff finds a way to

inform the public about the amount of emissions created by this

industry.


Failing to release generic statistics on releases of VOC’S or

toxins into the air because of patent issues isn’t really a valid

argument, although it is used in the food industry as well as the

various chemicals industries. (That’s why foods can say “natural

flavors” and have in it any ingredient with a primary purpose of

only adding flavor.) Please note: any of these products can be

deformulated by a laboratory in Florida which specializes in

deconstructing fragrance formulae for the industry. The claim

that a patent might be at risk is therefore invalid. Releasing

the total pounds of emissions no more reveals the exact formula

than does deformulation by gas chromatography. 


•	ASTRINGENT/TONER: VOC limits increased from 10% to 35%. Although

we support staff’s efforts to reduce the VOC limits for this

category, we would like to see a standardization of this industry.

Many manufacturers of non-medicinal, non-FDA regulated

astringent/toners already manufacture 10% VOC limit products. 


•	FABRIC SOFTENER-SINGLE USE DRYER PRODUCT: VOC limits increased

from .05% to .1%. 


•	GLASS CLEANERS (AEROSOL FORM): VOC limit increased from 8% to

10%; compliance dates increased from 2010 to 2012. 


•	MULTI-PURPOSE LUBRICANTS: Compliance date moved from 2012 to

2013. 


	We are very pleased and supportive, however, that staff added a

new VOC limit 	of 10% to be met in 2015 - one positive improvement

we support.


•	PENETRANT: Compliance dates increased from 2012 to 2013.

Additionally, we feel that technology allows and staff could have

set this category’s limit at 10%, instead of the 25% VOC limit

suggested. 


•	PERSONAL FRAGRANCE: Compliance dates increased from 2010 to

2014. Personal fragrances are a large emitter of VOCs in the

consumer products category (10.77 tpd), thus we are pleased staff

will remove grandfather clauses from all products with 20% or less

fragrance. However, staff should increase the scope of products

whose grandfather clause will be removed and strengthen the VOC

limits suggested—currently at 25%.

•	NON-CHEMICALLY CURING SEALANT: VOC limit increased from 0.5% to

1.5%.


CATEGORIES DELETED FROM THE DRAFT LANGUAGE


We have informed staff that we are concerned about removing the

following categories from the regulation draft. We ask CARB to

commit to reduce emissions from those products and set a

reasonable timeline to bring this category back.


•	LIQUID AIR FRESHENERS: It is our understanding that CARB learned

about a patent problem that might prevent them from demanding a

lower VOC limit. In addition to setting a reasonable timeline for

VOC reductions from this category, CARB staff needs to provide

stakeholders more details about the stumbling blocks. 


 


•	POST-SHAVE PRODUCTS: CARB staff was having a hard time coming up

with a good way to define post-shave products, such as skin

conditioners, as separate from aftershave products like fragrance.

CARB staff has indicated they need more time to develop this

subcategory, so they have pulled it from the proposed regulation.


As CARB weighs its decision to regulate these chemicals, we urge

you to work with other stakeholders and consider the health of

those who are most exposed, and to protect the health of the most

vulnerable among us. CARB’s own Resolution No. 05-28, approved on

March 17, 2005, in response to the Indoor Air Pollution in

California study, “directs staff to promote ‘Best Practices’ for

the... maintenance of school facilities...in conjunction with other

State agencies and relevant private sector groups.” 


These protections are critical in the work and home environment,

where exposure to emissions from products tends to be more than

outdoors. These emissions can be significantly influenced by

regulatory decisions. In this regard, spot removers and

cleaning/janitorial chemicals are particularly important.


Part of Cal-EPA’s mission is to ensure that environmental

regulations not only protect the environment but also protect

public health, water quality, and worker safety, while minimizing

waste generation. The agency has recognized this fact in a variety

of ways, most recently in the Green Chemistry Initiative. One of

the challenges is to ensure that toxics are not in products,

either by design or by accident. We encourage CARB to not only

choose the most environmentally friendly VOC limit but also one

that is health protective and in line with the laudable goals put

forward by the Green Chemistry Initiative. 


Again, thank you for your commitment to regulate VOCs in consumer

products. We are very hopeful about this regulation’s potential to

help protect the health of California residents, consumers and

workers who deal with these products on a daily basis. 


We look forward to continuing working with your staff on this

issue and urge you to include us in CARB’s decision making

process. 


Sincerely,


 

Luis R. Cabrales


Senior Campaign and Outreach Associate


Coalition for Clean Air


Charlotte Brody, RN


Executive Director


Commonweal


Elina Green, MPH


Program Coordinator


Long Beach Alliance for Children with Asthma


Jesse Marquez


Executive Director


Coalition for a Safe Environment


Neil Gendel


Director 


Healthy Children Organizing Project


Joel Ervice


Interim Director


Regional Asthma Management and Prevention (RAMP) Initiative


Bill Magavern


Director


Sierra Club California


Dori Gilels


Executive Director


Women's Voices for the Earth


Adrian Martinez


Project Attorney


Natural Resources Defense Council


Rachel L. Gibson


Environmental Health Advocate & Staff Attorney


Environment California


Andrea Ventura


Program Manager


Clean Water Action


Wafaa Aborashed 


Executive Director 


Bay Area Healthy 880 Communities-SL


Lenny Siegel


Executive Director


Center for Public Environmental Oversight


Angel De Fazio, BSAT


President


National Toxic Encephalopathy Foundation


M. Suzanne Murphy,


Executive Director


Worksafe, Inc.

Elise Miller 


Executive Director


Institute for Children's Environmental Health


Arturo Carmona 


Executive Director


Consejo de Federaciones Mexicanas en Norteamérica 


(COFEM)


Anne Katten


Pesticide and Work Safety Specialist


California Rural Legal Assistance Foundation


Teresa Marquez


Land use Committee Chair


Boyle Heights Resident Homeowners Association


James Roybal


President


Residents of Pico Rivera for Environmental Justice


Eden Flynn


Coordinator 


Southern California Coalition for Occupational Safety & Health 


(SoCalCOSH) 


Martha Dina Arguello


Executive Director


Physicians for Social Responsibility-Los Angeles


Deborah Moore


Executive Director


Green Schools Initiative


James Provenzano


President


Clean Air Now


René L. Guerrero


Legislative Advocate


Planning and Conservation League 


David Lighthall, Ph.D. 


Senior Scientist for Environmental Health, 


Central Valley Health Policy Institute*


(* For identification purposes only)


Bradley Angel


Executive Director


Greenaction for Health and Environmental Justice


Allyson Holman


Chair


Merced/Mariposa County Asthma Coalition


Jose Luis Olmedo


Executive Director


Comite Civico Del Valle

Conner Everts


Executive Director


Southern California Watershed Alliance


Miguel A. Luna


Urban Semillas


Julia Liou


Planning and Development Manager


Asian Health Services


Manuel Criollo


Lead Organizer 


Labor/Community Strategy Center


 


Cc (via electronic mail): 


 


James Goldstene


EO


jgoldste@arb.ca.gov


Carla Takemoto


Manager, Technical Evaluation Section


ctakemoto@arb.ca.gov 


David Mallory 


Measures Development Section Manager


dmallory@arb.ca.gov


Femi Olaluwoye


Regulatory Amendments


folaluwoye@arb.ca.gov


Attachment: www.arb.ca.gov/lists/cp2008/155-carbcconsumerproductsletter_062608.pdf

Original File Name: CARBCconsumerProductsLetter_062608.pdf 

Date and Time Comment Was Submitted: 2008-06-25 12:01:37

No Duplicates.
Comment 25 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Sean

Last Name: Fitzgerald

Email Address: Non-web submitted comment

Phone Number: 

Affiliation: 

Subject: National Aerosol Association

Comment:

Please see attached.

Attachment: www.arb.ca.gov/lists/cp2008/157-naa.zip

Original File Name: NAA.zip 

Date and Time Comment Was Submitted: 2008-06-25 14:57:07

No Duplicates.
Comment 26 for Consumer Products Regulations (cp2008) - 45 Day.

First Name: Rufus

Last Name: Howell

Email Address: Non-web submitted comment

Phone Number: 

Affiliation: 

Subject: California Department of Public Health

Comment:

Please see attached. 

Attachment: www.arb.ca.gov/lists/cp2008/158-ar-m355u_20080625_171647.pdf

Original File Name: AR-M355U_20080625_171647.pdf 

Date and Time Comment Was Submitted: 2008-06-27 15:09:22

No Duplicates.
Comment 1 for Consumer Products Regulations (cp2008). (At Board Hearing)

First Name: Linda

Last Name: Ray

Email Address: Non-web submitted comment

Phone Number: 

Affiliation: 

Subject: Statement for CARB Meeting

Comment:

Please see attached. 

Attachment: www.arb.ca.gov/lists/cp2008/159-cp2008.pdf

Original File Name: cp2008.pdf 

Date and Time Comment Was Submitted: 2008-07-01 16:05:57

No Duplicates.
Comment 2 for Consumer Products Regulations (cp2008). (At Board Hearing)

First Name: Barry

Last Name: Wallerstein

Email Address: Non-web submitted comment

Phone Number: 

Affiliation: 

Subject: South Coast AQMD

Comment:

please see attached

Attachment: www.arb.ca.gov/lists/cp2008/160-cp080002.pdf

Original File Name: cp080002.pdf 

Date and Time Comment Was Submitted: 2008-07-01 16:27:44

No Duplicates.
Comment 3 for Consumer Products Regulations (cp2008). (At Board Hearing)

First Name: Mark

Last Name: Sorenson

Email Address: Non-web submitted comment

Phone Number: 

Affiliation: 

Subject: Yorkshire Guttering

Comment:

please see attached

Attachment: www.arb.ca.gov/lists/cp2008/162-mark_sorenson.pdf

Original File Name: mark sorenson.pdf 

Date and Time Comment Was Submitted: 2008-07-01 16:32:01

No Duplicates.
Comment 4 for Consumer Products Regulations (cp2008). (At Board Hearing)

First Name: Rufus

Last Name: Howell

Email Address: Non-web submitted comment

Phone Number: 

Affiliation: 

Subject: CDPH

Comment:

please see attached

Attachment: www.arb.ca.gov/lists/cp2008/163-cp080003.pdf

Original File Name: cp080003.pdf 

Date and Time Comment Was Submitted: 2008-07-01 16:39:34

No Duplicates.
Comment 1 for Consumer Products Regulations (cp2008) - 15-1.

This comment was posted then deleted because it was unrelated to the Board item or it was a

duplicate.
Comment 2 for Consumer Products Regulations (cp2008) - 15-1.

First Name: Mike

Last Name: Flanagan

Email Address: advantagebp@aol.com

Phone Number: 

Affiliation: 

Subject: CP2008

Comment:

Dear Committee Members


Roof leaks and window leaks are nasty problems. The area is

usually wet and silicon sealants or latex sealants simply do not

work. Only a rubber sealant with a petroleum solvent allows

repairs to damp areas. I heard that California plans to ban all

petroleum solvents in sealants to protect houshold consumers.

Trained contractors need an exemption from this rule that will

allow them to select a rubber sealant having a petroleum solvent

that will fix the leaking problems permantly for the consumer.


Thank you for your consideration.


Mike Flanagan


President - Advantage Building Products

Attachment: 

Original File Name: 

Date and Time Comment Was Submitted: 2008-08-19 12:53:02

No Duplicates.
Comment 3 for Consumer Products Regulations (cp2008) - 15-1.

First Name: Jeremy

Last Name: Owens

Email Address: jeremy@3Generationsinc.com

Phone Number: 916-508-0020

Affiliation: 3 Generations Improvements

Subject: CA Consumer Products Regulations

Comment:

I was told recently that the caulking that I use to seal up my

customers' homes could be outlawed. We are a siding and window

contractor who use Quad and NPC sealant for sealing around

windows, doors, corners, etc. I use these petroleum based rubber

sealant's because it adheres the best in moist weather. Its

flexibility and ability to adhere during all weather conditions

has been the best for our business. We have tried using other

sealant's in the past and have had service claims where caulking

has cracked or deteriated within a few years.


When doing projects such as fiber cement, caulking is essential to

sealing up around windows and without the best sealant in the

market, we would be doing homeowners a dis-service. Please do not

outlaw these selaants or at least provide a contractor's exception!

 Thanks! 

Attachment: 

Original File Name: 

Date and Time Comment Was Submitted: 2008-08-21 14:15:20

No Duplicates.
Comment 4 for Consumer Products Regulations (cp2008) - 15-1.

First Name: D. Douglas

Last Name: Fratz

Email Address: dfratz@cspa.org

Phone Number: 

Affiliation: Consumer Specialty Products Association

Subject: 15-Day Notice of Public Availability of Modified Text

Comment:

Attached are CSPA comments on this notice.

Attachment: www.arb.ca.gov/lists/cp2008/171-cspa_comments_on_arb_15-

day_modified_text.pdf

Original File Name: CSPA Comments on ARB 15-Day Modified Text.pdf 

Date and Time Comment Was Submitted: 2008-08-25 13:48:41

No Duplicates.
Comment 5 for Consumer Products Regulations (cp2008) - 15-1.

First Name: Darlene 

Last Name: Coe

Email Address: darcoe@velotech.net

Phone Number: (530) 623-4360

Affiliation: DARCO Sales

Subject: Consumer Products Regulation on Sealants

Comment:

I have sold building products for the last 25 years. The last 4

years I have immersed myself in "Moisture Management" in

construction, both new and remodel. I have seen sealant failures

due to substandard sealants. I have also dealt with contractor

frustration when a silicone sealant just won't stick to a damp

surface, nor could they paint over it. Professional sealants,

those that include petroleum solvents, have proven to be the only

year-round sealant contractors can use with confidence. I have

seen the destruction leaks have caused around windows, on roofs

and behind siding. Many homes have become uninhabitable due to

these leaks and either the new homeowner is stuck with a home they

can't resell or the builder is forced to spend thousands of dollars

to correct the problem. California MUST allow contractors to be

exempt from this ruling. Quality construction is a must and

professional sealants are insurance they are doing everything

possible to prevent mold issues and serious water damage. Please

consider these issues and reduce all of the litigation that will

result by restricting contractors on the sealants they can use and

the seasons they can work.

Attachment: 

Original File Name: 

Date and Time Comment Was Submitted: 2008-08-26 11:59:53

No Duplicates.
Comment 6 for Consumer Products Regulations (cp2008) - 15-1.

First Name: Richard

Last Name: Arnett

Email Address: rarnett@sbcglobal.net

Phone Number: 

Affiliation: Vinyl Designs Inc.

Subject: CA Consumer Products Regulation cp2009

Comment:

I have heard that the caulking that most of the siding ,window and

PatioCover contractors are using at this time are going to be

taken off the market(California only).We currently use petroleum

based rubber sealant's because it adheares best in wet weather or

under damp conditions. If we are limited to Silicone based

sealants, only, then the call back rate to product failure will

skyrocket. We believe in giving our customers the best quality

installation possiable and we can not do that with current

silicone product that are on the market today. 


Please DO NOT OUTLAW THESE SEALANTS BUT IF YOU DO PLEASE MAKE IT

AN EXCEPTION FOR "CONTRACTORS USE ONLY"

Attachment: 

Original File Name: 

Date and Time Comment Was Submitted: 2008-08-26 13:11:16

No Duplicates.