1667 K Street NW, Suite 300 | Washington, DC 20006 | www.cspa.org | 202-872-8110

November 20, 2012 via electronic transmission

Clerk of the Board

Air Resources Board 

1001 I Street, 23rd Floor

Sacramento, California 95814

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

Subject: 15-Day Notice of Modifications to California Regulation for Automotive Windshield 

Washer Fluid (AWWF) Products; Board Resolution 12-321

Dear Board Members:

The Consumer Specialty Products Association (CSPA)2is on record supporting the amendments to 

California Regulation related to the AWWF product category3and appreciates the opportunity to 

offer comments on the modification set forth in Attachment B to Board Resolution 12-32.4 

CSPA supports the inclusion of an additional ZIP code in San Bernardino County to the Type “A” 

area listed in Table 94508(a)(20)(B). As noted during the Board’s public hearing, this particular area 

of San Bernardino County experiences freezing temperatures during the winter months. Thus, the 

modification will further enhance public safety by eliminating potentially hazardous conditions that 

could occur if: (1) the AWWF froze in the residents’ automobile windshield washer reservoirs; or 

(2) froze when applied to the windshield while residents are driving. 

If you have any questions, please contact us at (202) 872-8110.

Respectfully submitted,

D. Douglas Fratz Joseph T. Yost

Vice President, Scientific & Technical Affairs Senior Director, Strategic Issues Advocacy

Kristin Power

Director, State Affairs – West Region

 

1 Board Resolution 12-32 is posted on the ARB website at: http://www.arb.ca.gov/regact/2012/cp2012/res12-32.pdf.

2 CSPA is a voluntary, non-profit national trade association representing approximately 230 companies engaged 

in the manufacture, formulation, distribution, and sale of products for household, institutional, commercial and industrial 

use. CSPA member companies' wide range of products includes home, lawn and garden pesticides, antimicrobial 

products, air care products, automotive specialty products, detergents and cleaning products, polishes and floor 

maintenance products, and various types of aerosol products. Through its product stewardship program Product Care®, 

and scientific and business-to-business endeavors, CSPA provides its members a platform to effectively address issues 

regarding the health, safety, sustainability and environmental impacts of their products.

3 CSPA filed written comments on October 15, 2012, and presented oral testimony at the Board’s public hearing 

on October 18, 2012.

4 The text of Attachment B is posted on the ARB website at: http://www.arb.ca.gov/regact/2012/cp2012/cp2012.htm.
CSPA Comments on the 15-Day Notice of Modifications to Board Resolution 12-32

November 20, 2012

Page 2 of 2

cc: Carla D. Takemoto, Chief, Area Source and Emissions Inventory Programs Branch, PTSD

Jose Gomez, Manager, Technical Development Section, Area Source and Emissions 

Inventory Programs Branch, PTSD

Olufemi Olaluwoye, Air Pollution Specialist, Technical Development Section, Area Source 

and Emissions Inventory Programs Branch, PTSD

CSPA Air Quality Special Committee and Automotive Products Task Force

Laurie E. Nelson, Randlett Nelson Madden Associates