## 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 95812Via 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 staffproposal, 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. CARBstaff 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 believecould 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 ValleConner 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.