Technical Support Document Chapter VI - 74 

Table VI-6 

Dusting Aid Proposal*

Product Form

Proposed 

VOC Limit 

(wt. %)

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emission 

Reductions 

(lbs/day)** 

2010 

Emission 

Reductions 

(lbs/day)+

Aerosol 17 13 5 151 155 

Non-aerosol 3 33 77 0 0 

Total ------ 46 ------ 151 155 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a). 

** Emission reductions adjusted for complete market coverage and grown, by population, to 2008 

(see Chapter IV, Emissions). 

+ Emission reductions adjusted for complete market coverage and grown, by population, to 2010 

(see Chapter IV, Emissions). 

REFERENCES 

1. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

November, 2004. (ARB, 2004a) 

2. Air Resources Board. Proposed Amendments to the Statewide Regulation to 

Reduce Volatile Organic Compound Emissions from Consumer Products –

Phase II – Technical Support Document. October, 1991. (ARB, 1991a) 

4. Fabric Protectant (non-aerosol)

Product Category Description: 

 Fabric Protectants are applied to fabric substrates to protect the surface from dirt, 

soil, and other contaminants, and from stains that may result. While some products 

also provide water repellency, Fabric Protectants are used specifically to protect against 

dirt, soil, or stains. Products which solely provide water repellency (i.e. water-proofing 

protection), without any claim for dirt, soil, or stain protection, are considered 

Waterproofer products, and are not included in the Fabric Protectant category. 

Typically, Waterproofer products are silicone-based, while some Fabric Protectant 

products (notably the aerosols) are fluoropolymer-based (ARB, 1991a). 

 Fabric Protectants were regulated under Phase II of the Consumer Products 

Regulation adopted in January 1992, and a description of the product category is also 

included in the staff report for that rulemaking (ARB, 1991a). At that time, the Board 

approved the staff recommendation of a 75 percent VOC limit for all product forms 

effective January 1, 1995, along with a 60 percent VOC limit for all product forms 

subsequently effective January 1, 1997. The 60 percent VOC limit for all product forms 

remains in effect. 
Technical Support Document Chapter VI - 75 

 The current proposal for a specifying a lower VOC limit pertains only to the nonaerosol products, for reasons discussed later. Table VI-7 below summarizes the sales 

and emissions from ARB’s 2003 Survey (ARB, 2004a). The data have been grown to 

the 2008 calendar year. Total category sales are about 5,517 pounds per day. 

Table VI-7 

Fabric Protectant* 

Product Form

Number of 

Products

2008 

Category Sales 

(lbs/day)**

2008 Adjusted 

VOC Emissions 

(lbs/day)**

Non-Aerosol 63 5,517 366 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a).

** Survey data adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions).

 Estimated VOC emissions of non-aerosol Fabric Protectants are 366 pounds per 

day, or about 0.18 tons per day. Although not shown, the sales-weighted average VOC 

content for this category is 5 percent by weight. 

Product Use and Marketing: 

 Fabric Protectants are used by household consumers and outdoor recreational 

enthusiasts; as well as commercial and professional workers for clothing care, 

upholstery care, carpet care, and automotive interior care. Fabric Protectants may be 

used for household fabric articles such as bed covers, quilts, craft, and vehicle 

upholstery. Fabric Protectants are also used on the fabric tops of convertible 

automobiles. 

 Non-aerosol products are typically applied by mechanical spray on clean fabric 

articles, and left to dry. A resin film, usually very thin and often invisible, is formed and 

left behind on the fabric fibers. Occasional re-application may be needed to maintain 

protection (ARB, 1991a). 

 Fabric Protectants are sold in general merchandise stores, supermarkets, 

hardware stores, recreational equipment stores, auto parts stores, janitorial and 

maintenance supply warehouses, and over the Internet. 

Product Formulation: 

 The non-aerosol products are liquid, mechanical-spray-applied products, some 

sold as dilutables (i.e. concentrates). Most formulations are water-based with low levels 

of VOCs. Typical VOCs include glycol ethers and alcohol. Non-VOC products 

represented approximately 42 percent of the non-aerosol sales. The sales-weighted 

average VOC content of the products reported in the 2003 Survey was 5 percent by 

weight. 
Technical Support Document Chapter VI - 76 

Proposed VOC Limit and Compliance: 

 The proposed VOC limit for non-aerosol products is 1 percent VOC by weight, 

effective December 31, 2010. As shown in Table VI-8, using emissions adjusted to 

2010, the proposed limit will result in an estimated emission reduction of 163 pounds 

per day, or about 0.08 tons per day. Table VI-8 also shows that about 95 percent of the 

non-aerosol market currently complies with the proposed 1 percent VOC limit. 

Table VI-8 

Fabric Protectant Proposal*

Product Form

Proposed 

VOC Limit 

(wt. %)

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emission 

Reductions 

(lbs/day)** 

2010 

Emission 

Reductions 

(lbs/day)+

Non-Aerosol 1 42 95 159 163 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a). 

** Emission reductions adjusted for complete market coverage and grown, by population, to 2008 

(see Chapter IV, Emissions).

+ Emission reductions adjusted for complete market coverage and grown, by population, to 2010 

(see Chapter IV, Emissions).

 The proposed 1 percent VOC limit is intended to allow for complying water-based 

formulations. As discussed above, the 2003 survey data showed many non-aerosol 

products are water-based and already are low or non-VOC. 

 The 2003 survey data show very limited use of perchloroethylene (an exempt 

chlorinated compound) and trichloroethylene (a VOC chlorinated compound) in this 

category. While it is not likely these toxic air contaminants will be used as cleaning 

solvents in the future reformulated products, ARB staff is proposing that 

perchloroethylene, trichloroethylene, and methylene chloride be prohibited from use in 

Fabric Protectant products. This prohibition is proposed to ensure that manufacturers 

do not choose to reformulate with toxic chlorinated solvents in response to the lower 

VOC limits. Staff has determined that currently available formulation technologies do 

not contain perchloroethylene, trichloroethylene, or methylene chloride, thus they are 

not needed to comply with the proposed standard. See Chapter VIII for a discussion of 

the health effects of perchloroethylene, trichloroethylene, and methylene chloride. 

Issues:

a. Issue: The proposed 1 percent VOC limit for non-aerosol Fabric Protectants 

may be feasible for some types of products, but not others. 

Response: The commenter did not identify which types of products for which 

the proposal may not be feasible. A review of labels for products that comply 

with the proposed standard shows a variety of claims, demonstrating the 

proposal is feasible for many types of products. No specific claims were found 
Technical Support Document Chapter VI - 77 

on the labels of non-complying products that could not also be found on the 

labels of complying products. In addition, the large complying market share for 

the non-aerosol products suggests that the proposal is feasible. 

b. Issue: The proposed VOC limit for aerosol products is not feasible for products 

labeled for use on upholstery. 

Response: Regarding the aerosol products, ARB staff believes that survey year 

2003 was likely within the transition period during which industry conducted 

research and development and phased in replacement products using new 

chemical technologies, following the phase-out of the perfluorooctanyl chemistry 

products at the end of 2000 (3M, 2007; 3M, 2000a; 3M, 2000b; U.S. EPA 2000). 

Also, five years have passed since the 2003 survey, so current products may be 

the result of several transitional changes. Therefore, products marketed now 

may be substantially different in terms of product formulations, sales, and 

possible VOC emission reductions, compared with the products in the 2003 

survey. Staff therefore plans to defer proposing a VOC standard for aerosol 

Fabric Protectants and intends to re-survey the aerosol products to obtain more 

representative data. Staff will reconsider the VOC limit for aerosol products in a 

future rulemaking, assuming that the phase-in of new technologies has largely 

been accomplished. 

REFERENCES 

1. 3M. What you should know about 3M’s ‘next generation’ ScotchgardTM Protector 

products. 2007. 

http://solutions.3m.com/wps/portal/3M/en_US/Scotchgard/Home/Resources/Envi

ronmental. October 29, 2007. (3M, 2007) 

2. 3M. RE: Phase-out Plan for POSF-Based Products. July 7, 2000. 

http://www.fluoridealert.org/pesticides/pfos.fr.final.docket.0009.pdf. 

(July 10, 2000). (3M, 2000a) 

3. 3M. 3M Phasing Out Some of its Specialty Materials. May 16, 2000. 

http://www.chemicalindustryarchives.org/dirtysecrets/scotchgard/pdfs/226-

0641.pdf#page=1. (September 1, 2000). (3M, 2000b) 

4. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

 November, 2004. (ARB, 2004a) 

5. Air Resources Board. Proposed Amendments to the Statewide Regulation to 

Reduce Volatile Organic Compound Emissions from Consumer Products - Phase 

II – Technical Support Document. October, 1991. (ARB, 1991a) 
Technical Support Document Chapter VI - 78 

6. United States Environmental Protection Agency. Memo from Charles Auer to 

Barbara Leczynski, Mary Dominiak, Frank Kover, Ward Penberthy, and Karen 

Lannon. Subject: Phaseout of PFOS. May 16, 2000. (U.S. EPA, 2000) 

5. Fabric Softener – Single Use Dryer Product 

Product Category Description: 

Fabric Softener – Single Use Dryer Product is a laundry care product designed or 

labeled for single use in the clothes dryer to impart softness to, or control static cling of, 

a load of washable fabrics; and may impart a fragrance or scent. For the purpose of 

this definition only, “single use” means a product that is intended for one time use during 

a single drying cycle and is removed after completion of the drying cycle. A “load” is the 

amount of washable fabrics in a single drying cycle. Fabric Softener – Single Use Dryer 

Product includes treated non-woven sheets which are typically packaged in boxes with 

a multiple number of sheets. Fabric Softener – Single Use Dryer Product does not 

include products applied to washable fabrics prior to placing the washable fabrics in the 

clothes dryer and multiple use dryer-added products. 

These products are often sold in packages of as little as 20 sheets to as many as 

200 sheets per box and are available in both scented and unscented varieties. A 

product brand may have more than one fragrance variant. Based on the shelf survey 

conducted by ARB staff in 2006 and Internet searches, the majority of dryer-added 

fabric softener products are sold as single use sheets but are also available to 

consumers in multiple use products such as packets, sachets, blocks and dryer balls. 

However, the Fabric Softener – Single Use Dryer Product category only applies to 

single use products. 

 Fabric Softener – Single Use Dryer Product is a previously unregulated category. 

Table VI-9 below summarizes the sales and emissions from products in the Fabric 

Softener – Single Use Dryer Product category based on the results of ARB’s 2003 

Survey (ARB, 2004a). The data have been grown to the 2008 calendar year. Total 

category sales are about 26,804 pounds per day. 
Technical Support Document Chapter VI - 79 

Table VI-9 

Fabric Softener--Single Use Dryer Product * 

Product Form

Number of 

Products

2008 

Category Sales 

(lbs/day)**

2008 Adjusted 

VOC Emissions 

(lbs/day)**

All Forms+26 26,804 1,037 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a). 

** Survey data adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions).

+ Only the amount of product impregnated on a sheet reported. The mass of the sheet is not 

included.

 As shown in Table VI-9, products in the Fabric Softener – Single Use Dryer 

Product category have estimated VOC emissions of about 1,037 pounds per day, or 

about 0.52 tons per day, in California. Although not shown, the SWA-VOC content for 

this category is about 4 percent by weight (including all fragrance but excludes the 

sheet) or about 0.08 grams of VOC per sheet. 

Product Use and Marketing: 

 Fabric softener products can often be found as liquid and sheet products. 

According to the Soap and Detergent Association (SDA), 86 percent of households use 

a fabric softener product; with 40 percent preferring a dryer-added sheet product, 

21 percent using a washer-added product, and 25 percent using both (SDA, 2006b). 

Dryer-added products are used to treat laundered fabrics in the clothes dryer. These 

products claim to soften clothes and eliminate static cling, or add a fresh scent. To 

impart softness refers to a “quality of the fabric in which its “hand” or feel to the touch is 

smooth, pliable and fluffy, as distinguished from coarse or scratchy” (US Patent, 2005). 

The term static cling refers to the “tendency of articles of clothing to adhere to one 

another after being dried in clothes dryer as a result of static electrical charges created 

on the surface of the fabric” (US Patent, 2005). 

 

The dryer-added and washer-added products provide the same softening and 

anti-static benefits. The dryer-added sheet products are perceived to be more 

convenient to use, being added into the clothes dryer as opposed to the washer rinse 

cycle. Dryer-added sheet products are generally sold as single use products. Single 

use and multiple use products refers to “the number of drying cycles in which the fabric 

treatment composition can be used and release an effective amount of a fabric 

treatment agent to fabric that is being dried during the operation of a dryer (US Patent, 

2007).” Typically, one sheet is used per drying cycle, with larger/atypical loads requiring 

up to two sheets per drying cycle. While dryer-added fabric softener products are more 

commonly used, liquid fabric softeners added to the clothes washer are more effective 

at softening clothes. This is because the wash water allows the softening ingredients to 

more easily penetrate into the fabric (SDA, 2006b). 

 
Technical Support Document Chapter VI - 80 

Both scented and unscented fabric softener products are marketed. According to 

the U.S. National Academy of Sciences, “15 percent of the U.S. population is 

hypersensitive to chemicals, including fragrances” (Clements, 2006). In order to meet 

market demand, companies have responded with unscented products. 

Fabric softener products are typically found in both household and commercial 

settings. They are available to consumers through national and private store label 

brands, with the national brands owning a large share of the market. Most fabric 

softener products are available for purchase in grocery stores, diversified pharmacies, 

warehouses, superstores, laundromats, and from Internet companies. 

Product Formulation: 

 Products in the Fabric Softener – Single Use Dryer Product category are 

formulated with cationic and nonionic softening agents, used to soften fabric and control 

static cling; water, used as a perfume carrier; fragrances, for aesthetic appeal; and/or 

inorganic materials such as preservatives, effective in “preventing biological degradation 

of the composition and substrate” (US Patent, 2005). These ingredients are typically 

impregnated on a non-woven sheet of synthetic fabric, and released by the heat and 

direct contact with the fabrics during the tumbling action of the clothes dryer. 

Dryer-added fabric softener products contain the same types of cationic 

compounds as those found in the washer-added fabric softener products, however, the 

dryer-added products contain alkyl sulfate salts instead of chloride salts (SDA, 2006a). 

The active ingredient consists of cationic fabric softening agents, known as quaternary 

ammonium compounds, used to impart softness to laundered fabrics. One side of the 

quaternary molecule contains a positively charged atom that binds to the negatively 

charged fabrics. The other side of the molecule consists of a long chain fatty material 

that leaves a coating on the fabric, making the fabric soft and controlling static cling 

(Kozen, 2006). Dryer-added fabric softener products may also contain long chain fatty 

based hydrocarbon nonionic molecules. “These nonionics have no positive charge but 

are effective in the dryer where deposition depends mostly on physical contact” (SDA, 

2006a). 

Along with its cationic and nonionic ingredients, dryer-added fabric softener 

products may also contain fragrances in their formulation. Data reported in the 2003 

Survey shows that the VOC ingredients found in dryer-added fabric softener products 

are mostly attributed to fragrances, with fragrance ranging from zero to 8 percent by 

weight (ARB, 2004a). According to the Fragrance Material Association (FMA), there are 

approximately 2,500 individual fragrance materials currently available, with mixtures of 

these materials containing as many as 50 to 300 individual chemical entities (FMA, 

2006). These fragrance materials may be naturally derived or synthetic, having a floral, 

woody or citrus scent. Because of the vast combination of mixtures to work with, 

companies are able to offer fabric softener products with different types of scents. 

 
Technical Support Document Chapter VI - 81 

Proposed VOC Limit and Compliance: 

 The proposed VOC limit for products in the Fabric Softener-Single Use Dryer 

Product category is 0.05 grams of VOC per use. Staff believes, and some industry 

stakeholders have agreed, that the proposed gram of VOC per use limit, instead of a 

percent by weight VOC limit, is more appropriate for this category as it would provide a 

level playing field and ensure that the size of the sheet substrate does not increase 

(SDA, 2008a). This proposed limit includes all VOCs in the product, including 

fragrance. 

Staff’s proposal for grams of VOC per use limit would provide a level playing field 

as manufacturers apply varying amounts of liquid to the sheet substrate and the VOC 

content on the sheet substrate may not be the same as the formulation of the liquid 

applied to the sheet during manufacture. As indicated by manufacturers, some of the 

water or fragrance in the liquid formulation could be driven off during the drying process. 

Also, a liquid with a lower VOC weight percent that is applied to the sheet in a large 

quantity could deposit more VOC on the sheet compared to a higher VOC weight 

percent liquid that is applied in a smaller quantity. 

The grams of VOC per use limit is designed to ensure that the size of the sheet 

substrate does not increase. In developing the limit for these products, staff determined 

that establishing a VOC percent by weight limit could result in manufacturers using 

larger size sheets to comply. This would diminish emissions reductions and potentially 

lead to increasing the solid waste stream. Therefore, to mitigate this potential and in 

accordance with the California Environmental Quality Act (CEQA), the grams of VOC 

per use limit is proposed. 

The 0.05 grams of VOC per use limit provides emission reductions equivalent to 

setting a 2.6 percent by weight VOC limit (including fragrance). Because the limit 

already accounts for the fragrance, there is no need for the fragrance exemption 

provided in section 94510(c) for these products (ARB, 2007a). This modification is 

proposed in section 94510(c). 

Compliance with the VOC limit shall be determined per sheet, or equivalent 

delivery substrate, based on the minimum recommended use for a single drying cycle 

specified on the product packaging or label. In other words, if one sheet is the minimum 

recommended use for a single drying cycle, then the VOC limit applies per sheet. If two 

sheets are the minimum recommended use for a single drying cycle, then the VOC limit 

applies to the aggregate VOC content in two sheets. “Minimum recommended use” 

does not include recommendations for incidental use of additional sheets, or equivalent 

delivery substrate, for limited applications such as for extra large or double loads of 

washable fabrics in large capacity clothes dryers. 

 

As shown in Table VI-10, using adjusted 2010 emissions, the proposed limit 

would result in an estimated emission reduction of 414 pounds per day, or about 
Technical Support Document Chapter VI - 82 

0.21 tons per day. Table VI-10 also shows that 24 percent of the market currently 

complies with the proposed 0.05 grams of VOC per use limit. This limit would become 

effective December 31, 2010. 

Table VI-10 

Fabric Softener – Single Use Dryer Product Proposal*

Product Form

Proposed 

Grams of 

VOC per 

Use Limit

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emission 

Reductions 

(lbs/day)** 

2010 

Emission 

Reductions 

(lbs/day)+

All Forms++ 0.05 20 24 404 414 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a).

** Survey emissions adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions).

+ Survey emissions adjusted for complete market coverage and grown, by population, to 2010 (see 

Chapter IV, Emissions).

++ Only the amount of product impregnated on a sheet reported. The mass of the sheet is not 

included. 

 In proposing this limit, we find that 24 percent of the market (20 out of 26 

products, both scented and unscented) complies with the proposed 0.05 grams of VOC 

per use limit (ARB, 2004a). The proposed limit will not require a change to the active 

ingredients or in the amount of active ingredients used in the formulation of the product. 

The active ingredients, LVP-VOCs, are not considered when determining compliance 

with the proposed limit, per the exemption provided in section 94510(d) (ARB, 2007a). 

 

As described above, the main ingredients found in dryer-added fabric softener 

products are cationic and nonionic softening agents also known as quaternary 

ammonium compounds, water, fragrances and inorganics. The active ingredients used 

are LVP-VOCs. The primary VOC ingredient in this category is the fragrance, which 

currently ranges from zero to 8 percent by weight (ARB, 2004a). Staff believes 

fragrance is the VOC ingredient most likely to be reduced in the reformulation of a 

product. Reformulation under the grams of VOC per use strategy would only require 

manufacturers to reduce the amount of fragrance while keeping the active ingredients 

the same. 

Although fragrances provide an important attribute for many customers, 

fragrances do not contribute to the primary function of softening fabric. Manufacturers 

should not have significant difficulty reformulating their products to meet the proposed 

limit of 0.05 grams of VOC per use. As indicated by the 2003 Survey, only a small 

number of companies would have to reformulate to meet this limit. Private label 

companies would not have to reformulate, but only request that their formulators use 

existing formulations which currently meet the proposed limit. 
Technical Support Document Chapter VI - 83 

Issues:

a. Issue: ARB has proposed a new category (Fabric Softener – Single Use Dryer 

Product) and definition that go substantially beyond the category covered by the 

2003 Consumer Product Survey. ARB surveyed for all the “sheet” form of dryer 

products and did not include “packets, sachets, and dryer balls.” 

Response: The CARB 2003 Consumer Products Survey not only surveyed for 

“Dryer Sheets” but “Other Laundry Products,” “In-Dryer Fabric Care” and “Fabric 

Softener.” All dryer-added products that were sold in California in 2003 should 

have been reported in one of these four categories. Dryer-added products are 

available not only as sheets, but in other forms. However, staff’s proposal only 

applies to singe use dryer products. 

b. Issue: The products reported in this category of the survey all appear to soften 

fabric. Although they may provide other benefits in terms of fabric care, their 

primary purpose is softening. Inclusion of products that “prevent static cling, 

reduce wrinkles, reduce drying time, [and] make ironing easier” would be 

inappropriate since it would capture products on the market now or in the future 

that are designed with these primary purposes and may not, as the category 

name implies, soften fabrics. 

Response: Based on staff evaluation of the product labels submitted by 

manufacturers, a large percent of products surveyed made claims of both 

softening as well as controlling static cling. ARB staff revised the definition as 

suggested by SDA but retained the anti-static property as this claim is often seen 

on the labels of most fabric softener products. 

c. Issue: Fragrance is a very desirable quality for consumers who use fabric 

softener sheets. If the amount of fragrance per softener sheet is reduced, 

consumers will use more to compensate. This will result in less emissions 

reduction achieved. There will be a significant impact on the environment from 

increased solid waste and shipping-related energy and air emissions. 

Response: While acknowledging that some consumers may increase their 

usage of fabric softener sheets in response to reduced fragrance, ARB staff does 

not believe that the proposed regulation will significantly increase consumer 

usage. No data were provided to support this claim. Consumer use data 

provided by SDA indicate that 80 percent of consumers use one sheet or less per 

drying cycle (SDA, 2008b). Increasing usage to two sheets would translate to 

added cost that many consumers may not be willing to pay. In addition, using 

two sheets would deposit more softening ingredients on the fabric and customers 

may notice a different “feel” to the fabrics. However, staff will use its periodic 

surveys to monitor product sales and take appropriate action if any unanticipated 

increased usage is occurring. 
Technical Support Document Chapter VI - 84 

d. Issue: The low market share, 24 percent, for existing products complying with 

the proposed 0.05 grams of VOC per use limit indicates that this limit is not 

technologically and commercially feasible. If sales of unscented products were 

excluded, then the complying market share is even lower. Customers will find 

that reformulated products will not meet their needs and switch to liquid fabric 

softener products. These products are heavier than dryer sheet products and 

are packaged in bulky plastic containers. This will result in a significant impact 

on the environment from increased solid waste and shipping-related energy and 

air emissions. 

Response: Staff disagrees. No data were provided to support this claim. The 

24 percent complying market share, with 20 complying products out of 

26 products, indicates that the proposed 0.05 grams of VOC per use limit is 

technologically and commercially feasible. However, staff intends to monitor 

product sales through periodic surveys, as is always done, to ensure that 

unintended consequences of establishing the proposed VOC limit does not 

occur. 

e. Issue: The up to 2 percent by weight fragrance exemption per section 94510(c) 

should be provided to Fabric Softener-Single Use Dryer Product. It sets a bad 

precedent to treat Fabric Softener-Single Use Dryer Product differently from 

other regulated product categories. 

Response: The softening and anti-static active ingredients in fabric softeners 

are LVP-VOCs. Fragrance, therefore, is the primary ingredient restrained by the 

proposed 0.05 grams VOC per use limit. The 0.05 grams of VOC per use limit 

provides emission reductions equivalent to setting a 2.6 percent by weight limit 

including fragrance (or a 0.6 percent by weight limit with the fragrance exemption 

in section 94510(c)). Because the proposed limit already accounts for the 

fragrance, there is no need for the fragrance exemption in section 94510(c). 

f. Issue: Manufacturers will have to consider increasing the sheet sizes. This will 

result in less emissions reduction achieved. There will be a significant impact on 

the environment from increased solid waste and shipping-related energy and air 

emissions. (This comment is in reference to an earlier staff proposal for a 

percent by weight limit). 

Response: Staff believes that the existing corporate environmental policies will 

not favor the option of increasing sheet size. In addition, staff’s proposal for a 

grams of VOC per use limit, instead of a percent by weight limit, mitigates the 

potential for increases in sheet sizes. 
Technical Support Document Chapter VI - 85 

REFERENCES 

1. Air Resources Board. The California Consumer Products Regulations. 

December, 2007. (ARB, 2007a) 

2. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

 November, 2004. (ARB, 2004a) 

3. Clement, Carla. Fragrance Facts. May, 2005. 

http://www.alive.com/3163a6a2.php?subject_bread_cramb=179. (August 15, 

2006). (Clement, 2006) 

4. Fragrance Materials Association. Presentation to ARB staff. July 24, 2006. 

 (FMA, 2006) 

5. Kozen, Frances. Liquid Surfactant on Dryer Sheets Coat Fabric, Eliminating

Cling. February 8, 2006. Cornell University. 

http://www.ccmr.cornee.edu/education/ask/index.html. (August 15, 2006). 

(Kozen, 2006) 

6. Soap and Detergent Association. Telephone Conference with ARB staff. 

April 10, 2008. (SDA, 2008a) 

7. Soap and Detergent Association. Comment Letter Re: Fabric Softeners – Dryer 

Sheets. February 1, 2008. (SDA, 2008b) 

 

8. Soap and Detergent Association. Facts About Laundry. 

http://www.cleaning 101.com/laundry/fact/fact_sheet4.html. (January 17, 2006). 

(SDA, 2006a) 

9. Soap and Detergent Association. Liquid Fabric Softeners and Dryer Sheets 

Presentation. July 24, 2006. (SDA, 2006b) 

10. United States Patent 7250393B2. Fabric Treatment Compositions and Methods 

for Treating Fabric in a Dryer. July 31, 2007. (US Patent, 2007) 

11. United States Patent, 20050020475. Fabric Softener System and Method for use 

in Clothes Dryer. January 27, 2005. (US Patent, 2005) 

6. Floor Maintenance Product

Product Category Description: 

 The Floor Maintenance Product category consists of products that are labeled as 

Spray Buff products as well as products labeled as maintainers and restorers. Products 
Technical Support Document Chapter VI - 86 

in this category are designed or labeled to restore, maintain, or enhance a previously 

applied floor finish. Spray Buff products are designed or labeled to be used in 

conjunction with a floor buffing machine and special pad. Floor maintainers or restorers 

are designed or labeled to be applied with a mop and burnished with a floor buffing 

machine. Though the application methods for these two types of products differ, their 

formulations are similar. This category does not include floor polish products, products 

designed solely for the purpose of cleaning, or products designed specifically for the 

use on marble floors. 

 Floor Maintenance Products are a previously unregulated category. Table VI-11 

below summarizes the sales and emissions from Floor Maintenance Products based on 

the results of ARB’s 2003 Survey (ARB, 2004a). Floor Maintenance Products have 

estimated VOC emissions of 194 pounds per day, or about 0.1 tons per day in 

California. 

Table VI-11 

Floor Maintenance Product* 

Product Form

Number of 

Products

2008 

Category Sales 

(lbs/day)**

2008 Adjusted 

VOC Emissions 

(lbs/day)**

All Forms 98 3,540 194 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a).

** Survey data adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions).

 As shown in Table VI-11, this category contains 98 products with sales of 

3,540 pounds per day. Although not shown, the sales-weighted average VOC content 

is about 5 percent by weight. 

Product Use and Marketing: 

 Floor Maintenance Products are primarily used by commercial/institutional users 

and are designed for use on finishes previously applied to resilient and non-resilient 

floors. These products are able to remove traffic damage, soils, and reduce 

maintenance costs by extending the time between topcoating and stripping the previous 

finish (Rohm and Haas, 2006). The process may take place in the presence of 

pedestrian traffic resulting in minimum floor down-time (Rohm and Haas, 2006). 

 Products labeled as Spray Buffs are applied to a clean and dry floor surface. The 

user or machine will spray the product in a small area of the floor, avoiding excess 

application or allowing the product to puddle. The final step is then to buff the product 

using a buffer or burnishing machine. 

 Products labeled as floor maintainers or restorers are usually applied to a clean 

and dry floor surface with a mop in a thin, even layer, avoiding using excess product or 
Technical Support Document Chapter VI - 87 

allowing the product to puddle. The user allows the product to dry (usually about 20 

minutes) before burnishing or buffing with a machine. 

 Floor Maintenance Products are sold to commercial and industrial 

establishments. They can be found at janitorial stores, the Internet, as well as through 

manufacturers’ and distributors’ sales representatives. 

Product Formulation: 

 Floor Maintenance Products are primarily composed of water and polymer solids. 

Other ingredients include coalescent aids and other modifiers (such as levelers, 

plasticizers, viscosity modifiers, etc.) that optimize product properties. The coalescent 

aids are typically volatile glycol ethers that help the polymer solids form a smooth 

continuous coating over the floor surface. 

Proposed VOC Limit and Compliance: 

 The proposed VOC limit for Floor Maintenance Products is 1 percent by weight, 

effective December 31, 2010. As shown in Table VI-12, using adjusted 2003 emissions, 

the proposed limit will result in an estimated emission reduction of 142 pounds per day, 

or about 0.07 tons per day, by 2010. Table VI-12 also shows that 53 percent of the 

market currently complies with the proposed 1 percent VOC limit. 

Table VI-12 

Floor Maintenance Product Proposal*

Product Form

Proposed 

VOC Limit 

(wt. %)

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emission 

Reductions 

(lbs/day)** 

2010 

Emission 

Reductions 

(lbs/day)+

All Forms 1 57 53 140 142 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a).

** Emission reductions adjusted for complete market coverage and grown, by population, to 2008 

(see Chapter IV, Emissions).

+

Emission reductions adjusted for complete market coverage and grown, by population, to 2010 

(see Chapter IV, Emissions).

 There are reformulation options available that make reductions in VOC content 

technologically and commercially feasible. We expect manufacturers of noncompliant 

products to reformulate similarly to the compliant products. We also expect the 

technology used to reformulate floor polish for resilient and non-resilient floors may be 

used to reformulate Floor Maintenance Products. A 1 percent VOC limit was set for 

Resilient and Non-Resilient Floor Polish products in 2006. Reformulation options that 

can be used to meet the proposed limit include the use of water, LVP-VOC hydrocarbon 

solvents, LVP-VOC glycol ethers, as well as non-VOC alternatives available for 

substitution. 
Technical Support Document Chapter VI - 88 

REFERENCES 

1. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

 November, 2004. (ARB, 2004a) 

2. Rohm and Haas. Presentation to ARB staff. June 2006 

(Rohm and Haas, 2006) 

7. Floor Polish or Wax: Wood Floor Wax

Product Category Description: 

 Floor Polish or Wax is divided into three subcategories: products for Resilient 

Flooring Material, products for Nonresilient Flooring Material, and Wood Floor Wax. 

Floor Polish or Wax products for Resilient and Nonresilient floors were regulated as part 

of the 2006 Amendments. The proposal described here relates to Wood Floor Wax 

products only. 

 Wood Floor Wax products are designed or labeled for use solely on wood floors. 

These products are designed to polish, protect, wax, condition, protect, temporarily seal, 

or otherwise enhance floor surfaces by leaving a protective finish that is designed or 

labeled to be periodically replenished. This category does not include Floor 

Maintenance Products, Floor Wax Strippers, or coatings subject to architectural 

coatings regulations. Wood Floor Wax products that claim to “clean and wax” or “clean 

and polish” are Wood Cleaner products. 

 Floor Polish or Wax products were first regulated under Phase I of the Consumer 

Products Regulation adopted in October of 1990, and a description of these products is 

also included in the staff report for that rulemaking (ARB, 1990b). At that time, the 

Board adopted a 90 percent VOC limit for products used on wood floors, effective on 

January 1, 1994. 

 Table VI-13 below summarizes the sales and emissions reported for Wood Floor 

Wax products, based on the results of ARB’s 2003 Survey (ARB, 2004a). The data 

have been grown to the 2008 calendar year. Total category sales are about 

136 pounds per day. 

 As shown in Table VI-13, Wood Floor Wax products have estimated VOC 

emissions of 112 pounds per day, or about 0.06 tons per day in California in 2008. 

Although not shown, the sales-weighted average VOC content is about 82 percent by 

weight. 
Technical Support Document Chapter VI - 89 

Table VI-13 

 Floor Polish or Wax: Wood Floor Wax* 

Product Form:

Number of 

Products

2008 

Category Sales 

(lbs/day)**

2008 Adjusted 

VOC Emissions 

(lbs/day)**

All Forms 7 136 112 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a). 

** Survey data adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions).

Product Use and Marketing: 

 Wood Floor Wax is used by general consumers, as well as commercial and 

institutional customers. Commercial and institutional products account for the majority 

of reported products and total sales. 

 These products are historically designed to provide a temporary, water resistant 

seal to a finished or unfinished wood floor. Unfinished wood flooring material is 

becoming increasingly rare as evidenced by small sales in this category. Today they 

are being replaced with factory sealed wood flooring material. Generally anhydrous 

wax-based products (such as a paste wax) are used on unsealed wood floors, whereas 

a wax-based, but not necessarily anhydrous product is used on sealed wood floors. 

Because there is a potential for “side-bonding” or water damage if water-based products 

are used on an unsealed wood floor, anhydrous products are still needed (Owens, 

2006). 

 Wood Floor Wax products are generally applied with a sponge or cloth to a dry 

floor, and are then rubbed into the wood in a circular motion and allowed to dry. 

Depending on the manufacturer recommendations, the final step may then be to buff 

the finish to a shine using a buffer or burnishing machine, or to polish by hand with a 

clean cloth. 

 Wood Floor Wax products are sold to household consumers, commercial, and 

industrial establishments. They can be found at janitorial stores, supermarkets, 

warehouse and hardware stores, and the Internet, as well as through manufacturers’ 

and distributors’ sales representatives. 

Product Formulation: 

 

Wood Floor Waxes typically contain a suspension of natural wax such as 

carnauba or montan or other polymer in a hydrocarbon solvent such as mineral spirits. 

A solid form of Wood Floor Wax is generally composed of approximately 70 percent 

solids (wax) and 30 percent hydrocarbon solvent or LVP-VOC solvent. A liquid form of 

wood floor wax is generally composed of a mixture of water, a polymer solid, and an 

LVP-VOC solvent. 
Technical Support Document Chapter VI - 90 

Proposed VOC Limit and Compliance: 

 The proposed VOC limit for Wood Floor Wax products is 70 percent by weight, 

effective December 31, 2010. As shown in Table VI-2, using adjusted 2003 emissions, 

the proposed limit will result in an estimated emission reduction of 24 pounds per day, 

or about 0.012 tons per day in 2010. 

 Table VI-14 does not show the number of complying products or complying 

marketshare due to data confidentiality. 

Table VI-14 

 Floor Polish or Wax: Wood Floor Wax Proposal*

Product Form

Proposed 

VOC Limit 

(wt. %)

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emission 

Reductions 

(lbs/day)** 

2010 

Emission 

Reductions 

(lbs/day)+

All Forms 70 *** *** 22 24 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a).

** Emission reductions adjusted for complete market coverage and grown, by population, to 2008 

(see Chapter IV, Emissions).

+ Emission reductions adjusted for complete market coverage and grown, by population, to 2010 

(see Chapter IV, Emissions). 

 Reformulation options for Wood Floor Wax products include the substitution of 

hydrocarbon solvents with LVP-VOC solvents. Manufacturers may also develop a 

polymer technology that requires less VOC solvent. A minimal number of product 

reformulations are anticipated, as the market for these products is small and is 

anticipated to continue to decrease. 

REFERENCES 

1. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

 November, 2004. (ARB, 2004a) 

2. Air Resources Board. Proposed Regulation to Reduce Volatile Organic 

Compound Emissions from Consumer Products – Technical Support Document. 

August, 1990. (ARB, 1990b) 

3. Owens, Joseph M. Presentation to ARB staff. August, 2006. (Owens, 2006) 
Technical Support Document Chapter VI - 91 

8. Glass Cleaner – aerosol

Product Category Description: 

Glass Cleaners are specialty cleaning products designed primarily for cleaning 

surfaces made of glass such as windows, mirrors, glass tabletops, and computer 

screens. However, the Glass Cleaner category does not include products designed 

solely for the purpose of cleaning optical materials used in eyeglasses, photographic 

equipment, scientific equipment and photocopying machines. Products marketed as 

“glass and surface cleaner” are not included in this category; they are regulated as 

General Purpose Cleaner. 

Glass Cleaners were first regulated under “Phase I” of the Consumer Products 

Regulation adopted in October of 1990, and a description of these products is also 

included in the staff report for that rulemaking (ARB, 1990b). At that time, the Board 

adopted a 12 percent VOC limit for these products which was effective on 

January 1, 1993. Although past regulatory actions resulted in significant emission 

reductions, we believe that technology now exists to further reduce VOC emissions from 

the aerosol product form. Therefore, we are proposing to amend the regulation to 

reduce the VOC content limit for aerosol Glass Cleaners to 10 percent by weight VOC. 

 Table VI-15 below summarizes the sales and emissions from aerosol Glass 

Cleaners based on the results of ARB’s 2003 Survey (ARB, 2004a). The data have 

been grown to the 2008 calendar year. Total category sales are about 6,087 pounds 

per day. 

Table VI-15 

Glass Cleaner – aerosol* 

Product Form

Number of 

Products

2008 

Category Sales 

(lbs/day)**

2008 Adjusted 

VOC Emissions 

(lbs/day)**

Aerosol 95 6087 663 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a). 

** Survey data adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions).

Estimated VOC emissions are 663 pounds per day, or about 0.33 tons per day. 

Although not shown, the sales-weighted average VOC content for this category is about 

11 percent. 

Product Use and Marketing: 

Aerosol Glass Cleaners are used by household, institutional and industrial users 

for cleaning surfaces made primarily of glass and may have additional claims for 

cleaning surfaces such as chrome and plastic which require a “non-streaking” cleaning 

performance – leaving no non-volatile residues which show up readily on such surfaces. 
Technical Support Document Chapter VI - 92 

They are marketed towards automotive, household, office, institutional, professional and 

other specialty uses. 

These products can be purchased through many sales outlets including grocery 

stores, discount stores, wholesalers, mass merchandisers, hardware stores, automotive 

parts stores, warehouse stores and home centers. These products are labeled primarily 

for use on glass. If the product makes a “multi-surface” claim on the front panel, it is 

categorized as a General Purpose Cleaner. 

Product Formulation: 

Glass Cleaners are typically formulated with a high water content. Short carbon 

chain alcohols (such as isopropyl alcohol or ethyl alcohol) and/or glycol ethers are used 

to dissolve oily soils. Trace amounts of surfactant are included to emulsify oily soils. 

The surfactant also creates a layer of foam which forms on the sprayed surface. This 

allows the product to cling to the surface making the cleaning agents more effective and 

preventing run-off while the user wipes the surface clean. Trace amounts of a suitable 

inorganic material prevent corrosion in the can. Fragrance imparts a pleasant odor into 

the air and contributes to the overall aesthetic of the product. It can also mask the 

solvent and ammonia odor, if present. Non-volatiles, also known as residuals, are left 

behind on the surface after the rest of the product evaporates and can contribute to 

streaking, and are, therefore, kept to a minimum in the formulation. All of the products 

reported in the 2003 Survey are propelled by hydrocarbon propellants, typically in the 4 

to 5 percent by weight range. 

Proposed VOC Limit and Compliance

 The proposed VOC limit for aerosol Glass Cleaners is 10 percent by weight, 

effective December 31, 2012. As shown in Table VI-16, using adjusted 2012 emissions, 

the proposed limit will result in an estimated emission reduction of 65 pounds per day, 

or about 0.03 tons per day. Table VI-16 also shows that 37 percent of the market 

currently complies with the proposed 10 percent VOC limit. 

Table VI-16 

Glass Cleaner – aerosol Proposal* 

Product Form

Proposed 

VOC Limit 

(wt. %)

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emission 

Reductions 

(lbs/day)** 

2012 

Emission 

Reductions 

(lbs/day)+

Aerosol 10 32 37 62 65 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a).

** Survey emissions adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions).

+ Survey emissions adjusted for complete market coverage and grown, by population, to 2012 (see 

Chapter IV, Emissions). 
Technical Support Document Chapter VI - 93 

The proposed standard for aerosol Glass Cleaner was established after review of 

the 2003 survey data, consultation with industry representatives, review of available 

literature materials, and analysis of the technological and commercial feasibility of the 

standard. 

 As shown in Table VI-16, over a third of the market currently meets the proposed 

10 percent VOC limit. These complying products are using a combination of alcohol 

and glycol ether solvents, and hydrocarbon propellant in order to reach the proposed 

10 percent VOC level. 

 

For most aerosol Glass Cleaners, the reformulation will involve replacing some of 

the VOC solvent and/or propellant with water. Many products at, or below, the 

10 percent VOC level already claim to clean glass while leaving the surface streakfree. Besides products categorized as Glass Cleaner, there is a substantial market 

volume of products making equivalent claims in addition to cleaning claims for other 

hard surfaces. 

 

 Reformulated products, while effective, may have different attributes than the 

consumer is used to for some products. Staff believes this will require extensive test 

marketing before bringing the reformulated product to market. For these reasons, staff 

believes more time for compliance is warranted. 

REFERENCES 

1. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

November, 2004. (ARB, 2004a) 

2. Air Resources Board. Proposed Regulation to Reduce Volatile Organic 

Compound Emissions from Consumer Products – Technical Support Document. 

August, 1990. (ARB, 1990b) 

9. Motor Vehicle Wash 

Product Category Description: 

 Motor Vehicle Wash means a product designed or labeled to wash, wash and 

wax, wash and shine, or wash and/or clean the exterior surfaces of motor vehicles. 

Motor Vehicle Wash includes, but is not limited to, products for use in commercial, fleet, 

hand, and “drive through” car washes, commercial truck washing or large vehicle 

washing stations, and vehicle dealers and repair shops, as well as products intended for 

household use. Motor Vehicle Wash does not include Bug and Tar Remover, Glass 

Cleaner, Engine Degreaser, Brake Cleaner, Tire or Wheel Cleaner, and products 

labeled exclusively for use on locomotives or aircraft. 

 Motor Vehicle Wash is a previously unregulated category. Table VI-l7 below 

summarizes the sales and emissions from Motor Vehicle Wash based on the results of 
Technical Support Document Chapter VI - 94 

ARB’s 2003 Survey (ARB, 2004a). The data have been grown to the 2008 calendar 

year. Total category sales are about 53,680 pounds per day. 

Table VI-17 

Motor Vehicle Wash*

Product Form

Number of 

Products

2008 

Category Sales 

(lbs/day)**

2008 Adjusted 

VOC Emissions 

(lbs/day)**

All Forms 366 53,680 752 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a).

** Survey data adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions). 

 Estimated VOC emissions are 752 pounds per day, or about 0.38 tons per day. 

Motor Vehicle Wash, while primarily marketed as liquid, can also be found in nonaerosol product forms such as solid, foam/mousse, mist/dispersed spray, and postfoaming gel. No aerosol products were reported in the 2003 Survey (ARB, 2004a). 

Although not shown, the sales-weighted average VOC content for this category is 

approximately 1 percent by weight. 

Product Use and Marketing: 

Motor Vehicle Wash products are sold to household or “do-it-yourself” 

consumers, commercial, and industrial establishments. They are to be used on the 

exterior surfaces of motor vehicles such as automobiles, vans, sport utility vehicles 

(SUV), motorcycles, commercial trucks and trailers, noncommercial trucks, service 

vehicles, and recreational vehicles. These products are used to safely remove dirt, 

grime, and other road soils from a variety of material surfaces including, but not limited 

to, painted metal, vinyl, and metallic trim. In some instances, the product cleans the 

vehicle and leaves a shine or wax finish in a single step. These one-step products are 

unlike wax products, which must be applied separately to a clean vehicle surface. Both 

“wash and shine” and “wash and wax” products are able to be applied to a dirty vehicle 

surface. 

For the “do-it-yourself” consumers, Motor Vehicle Wash products are available in, 

but not limited to, retail outlets such as supermarkets, diversified pharmacies, home 

improvement stores, auto supply stores, super stores, and specialty stores. Auto 

dealers, repair shops, catalog sales, and the Internet are additional marketing locations. 

For commercial and industrial businesses, products are available from manufacturers 

and/or distributors, warehouses, as well as the Internet and retail outlets. 

The majority of Motor Vehicle Wash products are sold as liquid concentrates and 

must be diluted prior to use. A typical dilution would be one ounce of Motor Vehicle 

Wash to one gallon of clean water. Directions for product use indicate that the water 

should be cool, and the solution should be applied to a cool surface with soft material. 

The directions also often direct consumers to wash vehicles from the top down and 
Technical Support Document Chapter VI - 95 

rinse after the wash is applied. Using a terry cloth towel or other material such as a 

chamois to remove water is recommended. 

Concentrated Motor Vehicle Wash products that are used in commercial 

establishments, such as car wash or auto detailing businesses, may be used in 

proportioning units through which the concentrate passes in order to achieve the proper 

dilution ratio. An example of a commercial dilution ratio can be 1 part product to 300 to 

500 parts water. After the wash cycle, vehicles are rinsed. Depending on the 

properties of the concentrate or other additives, vehicles may air dry or need to be dried 

either mechanically or by hand to avoid spotting. 

Product Formulation: 

Motor Vehicle Wash products are primarily very near-zero VOC water-based 

formulations. Surfactants are the active ingredient of the products in this category. 

These surfactants are typically detergents and comprise the LVP-VOC portion of the 

product. Typical formulations include water and a small amount of LVP-VOCs, or water 

and a small amount of inorganics, or water and both LVP-VOCs and inorganics. The 

VOCs used in this category include small amounts of 2-butoxyethanol and isopropyl 

alcohol. 

Proposed VOC Limit and Compliance: 

The proposed limit for Motor Vehicle Wash is 0.2 percent VOC by weight, 

effective December 31, 2010. The proposed limit is applicable to both ready-to-use and 

dilutable products. The limit applies to diluted products after the minimum dilution is 

made. As shown in Table VI-18, using adjusted 2010 emissions, the proposed limit will 

result in an estimated reduction of 284 pounds per day, or about 0.14 tons per day. 

Table Vl-18 also shows that 89 percent of the market currently complies with the 

proposed 0.2 percent VOC limit. 

Table Vl-18 

Motor Vehicle Wash Proposal* 

Product Form

Proposed 

VOC Limit 

(wt. %)

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emission 

Reductions 

(lbs/day)** 

2010 

Emission 

Reductions 

(lbs/day)+

All Forms 0.2 311 89 276 284 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a).

** Emission reductions adjusted for complete market coverage and grown, by population, to 2008 

(see Chapter IV, Emissions).

+ Emission reductions adjusted for complete market coverage and grown, by population, to 2010 

(see Chapter IV, Emissions). 

Reformulation options that could be used by manufacturers to meet the proposed 

limit include the use of water and LVP-VOC hydrocarbon solvents; water and 
Technical Support Document Chapter VI - 96 

inorganics; or water in combination with both LVP-VOC solvents and inorganics. 

Because there are many viable non-VOC alternatives available for substitution, we 

believe the proposed limit is commercially and technologically feasible. 

Issues:

a. Issue: Wash-and-wax should be removed from the definition as it is a different 

product “type” from wash and cleaner. 

Response: Staff maintains that motor vehicle “wash and wax” products and 

“wash and shine” products should be included in the definition because these 

products are marketed as vehicle washes and are formulated similarly. Both 

Motor Vehicle Wash ingredients and wax or shine ingredients are combined in 

the product and labeled to be applied to vehicles in the same manner as other 

Motor Vehicle Wash products. They are usually applied to dirty surfaces, unlike 

waxes which must be applied to clean surfaces. Retail outlets from 

supermarkets to superstores and auto supply stores, for example, stock and 

feature “wash and wax” and “wash and shine” products with other Motor Vehicle 

Wash products and not with vehicle wax products. 

b. Issue: Industry only assumed one product “type” (i.e., wash only products) when 

responding to the 2003 Consumer Products Survey and the data may not be 

available to support meeting the criteria for this new category. 

Response: Industry did not assume only one motor vehicle wash and cleaner 

product type when responding to the 2003 Consumer Products Survey. Twentyfive companies responded with 38 products that are either wash and wax or 

wash and shine which they identified as belonging in the vehicle wash category 

along with the other 300-plus products that were reported in the category. After 

considering dilution ratios, most of these products already comply with the 

proposed 0.2 percent VOC by weight limit. 

REFERENCES 

1. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

November, 2004. (ARB, 2004a) 

10. Multi-purpose Lubricant

Product Category Description: 

 Multi-purpose Lubricants are lubricant products designed for general purpose 

lubrication, or lubricants labeled for use in a wide variety of applications. This category 

includes products that are labeled for household use and for institutional and industrial 

use (for example, use by mechanics, professional contractors, and manufacturing 
Technical Support Document Chapter VI - 97 

facilities). This category includes products that are simply labeled as “lubricants;” multifunctional products that provide light duty lubrication; products labeled as aerosol spray 

greases; and liquid or aerosol products containing heavier base oils. This category 

includes multi-functional Multi-purpose Lubricants, which may also make claims to 

function as demoisturants, penetrants, and rust preventatives. 

 This category does not include specialty lubricant products, such as products 

labeled only for use on chains, even if the label specifies use on different types of 

chains. As defined in the Consumer Products Regulation, Multi-purpose Dry Lubricants, 

Penetrants, and Silicone-based Multi-purpose Lubricants are excluded from the Multipurpose Lubricant category. The Multi-purpose Lubricant category also excludes 

lubricant products that are (1) sold exclusively to establishments which manufacture or 

construct goods or commodities, and are (2) labeled “not for retail sale.” Automotive 

power steering fluids, lubricant products for use inside power generating motors, 

engines, and turbines, and their associated power-transfer gearboxes, two cycle oils or 

other products designed to be added to fuels, and products for use on the human body 

or animals are excluded from this category as well. Multi-purpose Lubricant products 

that are marketed in solid and semisolid-forms, as defined in the Consumer Products 

Regulation, are excluded from this category. 

 Multi-purpose Lubricants were first regulated under “Midterm Measures I” of the 

Consumer Products Regulation approved in July of 1997, and a description of these 

products is also included in the staff report for that rulemaking (ARB, 1997b). At that 

time, the Board adopted a 50 percent by weight VOC limit for these products which 

became effective on January 1, 2003. 

 Table VI-19 below summarizes the sales and emissions from Multi-purpose 

Lubricants based on the results of ARB’s 2003 Survey (ARB, 2004a). The data have 

been grown to the 2008 calendar year. Total category sales are about 16,337 pounds 

per day. 

Table VI-19 

Multi-purpose Lubricant* 

Product Form

Number of 

Products

2008 

Category Sales 

(lbs/day)**

2008 Adjusted 

VOC Emissions 

(lbs/day)**

Aerosol 146 11,568 5,784 

Liquid 30 4,769 2,384 

Total 176 16,337 8,168 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a); Includes products 

containing exempt chlorinated solvents. 

** Survey data adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions). 
Technical Support Document Chapter VI - 98 

Estimated 2008 VOC emissions for Multi-purpose Lubricants are 8,168 pounds 

per day, or about 4.08 tons per day in California. Table VI-19 shows the lubricant 

products separated into aerosol and liquid forms, with the aerosol form dominating the 

market in both sales and emissions. According to our data, the sales-weighted average 

VOC content for this category is about 48 percent by weight. 

 

Product Use and Marketing: 

 Multi-purpose Lubricants are used by household, institutional, and industrial 

users. Household consumers use multi-purpose lubricants on a variety of objects, 

including door hinges, bicycle chains, garage door tracks, window tracks, camping and 

sporting equipment, gardening tools, locks and firearms. Institutional and industrial 

consumers use Multi-purpose Lubricant products on the above mentioned items, as well 

as on more specialized equipment such as conveyors, open gears, electrical 

equipment, nuts, bolts, cables, and machinery. 

 Some Multi-purpose Lubricants are designed to deposit a heavier coating that 

provides lubricity under higher loads. These products include aerosol spray greases, 

such as “white lithium grease;” liquid or aerosol lubricants containing heavier base oils; 

and lubricants that provide extra protection against corrosion. 

 The Multi-purpose Lubricant category includes multi-functional products that are 

typically designed to provide a light lubricant film that penetrates surfaces, displaces 

water and inhibits rust and corrosion (ARB, 2004a). They are more often used for light 

duty lubrication, or for use as a penetrant, demoisturant, or for corrosion prevention. 

Typical applications include lubrication of locks or sliding mechanisms. 

 Multi-purpose Lubricants for household use are sold in various retail venues such 

as hardware stores, supermarkets, do-it-yourself home building supply stores, on the 

Internet, and everywhere automotive supplies are sold. Products may also be sold to 

institutional users through distributors. 

Product Formulation: 

 Multi-purpose Lubricants provide lubrication through use of base oils. These 

base oils are typically various grades of petroleum oils or greases. In some cases, 

synthetic oils are used. The balance of the product is usually a hydrocarbon solvent 

which may be a VOC, a LVP-VOC, or a mixture of VOC and LVP-VOC hydrocarbon 

solvents. A small number of products use chlorinated solvents. The propellant, in 

aerosol products, is either a liquefied petroleum gas or carbon dioxide. After the 

product is sprayed, the solvent and propellant evaporate away, leaving a coating of oil 

or grease. Liquid products are typically comprised of pure base oils, or base oils 

thinned in any of the solvents used in aerosol products. 

 The oils or greases used in aerosol Multi-purpose Lubricants constitute 

approximately 15 to 40 percent of the formulation by weight (ARB, 2004a). The base 
Technical Support Document Chapter VI - 99 

oils, are generally chosen based on their viscosity and typically consist of highly refined 

aliphatic or naphthenic hydrocarbon mixtures. Some Multi-purpose Lubricants, such as 

aerosol spray greases, use synthetic oils in their formulations (ARB, 2004a). 

 The solvents used in Multi-purpose Lubricants comprise 35 to 90 percent of 

aerosol formulations. Various grades of petroleum distillates are used. VOC solvents 

used include heptanes, hexanes, toluene, trichloroethylene, and glycol ethers. 

LVP-VOC hydrocarbon solvents are also used. 

 The propellants used in aerosol Multi-purpose Lubricants are either liquefied 

petroleum gases (propane, isobutane, normal butane), or carbon dioxide. Liquefied 

petroleum gases constitute approximately 20 to 30 percent of the product weight, 

compared to 2 to 3 percent when carbon dioxide is used. 

 Specialized extreme pressure additives may also be added in small amounts to 

Multi-purpose Lubricant formulations to enhance the ability of the base oil to protect 

surfaces under high load conditions. These specialized additives include graphite, 

Teflon (polytetrafluoroethylene), and “moly” (molybdenum disulfide). Multi-purpose 

Lubricants that contain these additives are not considered Multi-purpose Dry Lubricants. 

 Multi-purpose Dry Lubricants provide lubricity solely through use of graphite, 

molybdenum disulfide, or polytetrafluoroethylene or closely related fluoropolymer. Multipurpose Dry Lubricants do not contain oils. The proposed amendments include a 

modification to the Multi-purpose Dry Lubricant definition. The proposed modification 

clarifies that lubricity is provided solely by these compounds. The modification is 

intended to clearly distinguish these products from Multi-purpose Lubricants. 

 Corrosion inhibitors may also be added to Multi-purpose Lubricant formulations to 

prevent corrosion on the coated surfaces. These compounds generally make up a 

small percentage of the overall lubricant formulation and they may consist of organic 

acids, esters, amino acid derivatives, and various alkaline compounds. 

 Aerosol spray greases (i.e. white lithium grease, or red grease) are Multi-purpose 

Lubricants made up of oils which are thickened with a “metal soap,” such as lithium 

hydroxystearate) or a gelling agent, such as silica or clay. 

Proposed VOC Limit and Compliance: 

 We are proposing two tiers of VOC limits for Multi-purpose Lubricants. The first 

tier VOC limit for Multi-purpose Lubricants is 25 percent by weight for both aerosol and 

liquid forms, effective December 31, 2013. As shown in Table VI-20, using adjusted 

2003 emissions, the proposed limit will result in an estimated VOC emission reduction 

of 4,084 pounds per day, or about 2 tons per day, in 2013. A technology-forcing second 

tier VOC limit of 10 percent VOC by weight, effective December 31, 2015, is also 

proposed. As shown in Table VI-20, the 10 percent limit would reduce emissions by 
Technical Support Document Chapter VI - 100 

2,545 pounds per day, or about 1.3 tons per day. When fully effective, these two limits 

would reduce emissions from Multi-purpose Lubricants by about 3.3 tons per day. 

 

 Table VI-20 also shows that 38 products, representing approximately 4 percent of 

the total Multi-purpose Lubricant market, currently comply with the proposed 25 percent 

VOC limit. Table VI-20 also shows that 22 products, representing 3 percent of the 

market currently comply with the proposed 10 percent limit. Only those products 

complying without the use of methylene chloride, perchloroethylene, and 

trichloroethylene, are included in the complying market share data. The complying 

products include both aerosol and liquid Multi-purpose Lubricants for household, 

commercial and institutional use. 

Table VI-20 

Multi-purpose Lubricant Proposal*

Product 

Form

Proposed 

VOC Limit 

(wt. %)

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emission 

Reductions 

(lbs/day)** 

Emission 

Reductions 

(lbs/day)+

25 27 3 2,748 2,924 Aerosol 

10 11 2 1,677 1,827 

25 11 6 1,090 1,160 

Liquid 

10 11 6 659 718 

25 38 4 3,838 4,084 

Total 

10 22 3 2,336 2,545 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a). 

** Emission reductions adjusted for complete market coverage and grown, by population, to 2008 

(see Chapter IV, Emissions). 

+ Emission reductions adjusted for complete market coverage and grown, by population, to 2013 

for the 25% VOC limit; and to 2015 for the 10% VOC limit (see Chapter IV, Emissions). 

 The proposed VOC limits are designed to restrict the use of VOCs in Multipurpose Lubricant formulations. Reformulation options include adding more base oil to 

the formulation; replacing some of the VOC solvents with LVP-VOC solvents; and using 

carbon dioxide as an alternative to liquefied gas hydrocarbon propellants. 

 We believe that the small complying market shares demonstrate that the 

VOC limits are feasible, but challenging - especially for aerosols. Therefore, staff is 

proposing extended effective dates for the limits. As proposed, the compliance date to 

meet the 25 percent limit is December 31, 2013. The 10 percent limit is proposed to 

become effective on December 31, 2015. The second tier technology-forcing limit of 

10 percent is designed to encourage manufacturers to explore emerging technologies. 

Staff’s research indicates that use of materials such as soy-based products provide a 

partial path forward. However, maintaining many other attributes of Multi-purpose 

Lubricants will require extensive research and development. 
Technical Support Document Chapter VI - 101 

 While the reformulation options may appear straight-forward, maintaining existing 

lubricity and evaporative characteristics will be challenging. As mentioned earlier, Multipurpose Lubricants may also function as demoisturants, penetrants, and rust inhibitors. 

Research to find additives for corrosion protection and to maintain the products’ 

penetrating ability will be required. Utilizing emerging technologies in an aerosol 

product also presents challenges. Many reformulated products, while effective, may 

have different attributes than the consumer is used to. Staff believes this will lead to 

extensive test marketing before bringing the reformulated products to the market. For 

these reasons, staff believes additional time is needed to successfully reformulate and 

bring products into the market. 

 The Institute for Research and Technical Assistance (IRTA)conducted lubricant 

research in 2004 and 2006 with a focus on finding alternatives to high VOC 

petroleum-based and chlorinated oils. The alternatives that IRTA tested, and 

demonstrated in the industrial setting during the two projects, were water-based and 

vegetable-based products. Some businesses have been using these products as 

cutting oils or for honing, machining, or stamping (IRTA, 2006; IRTA, 2004). These 

operations are not typical consumer uses. We also note the products used were not 

aerosols, which household consumers prefer. Nevertheless, we believe, given more 

time, that Multi-purpose Lubricant products, including aerosols, could be formulated to 

lower VOC levels. 

 While staff believes that technologies are progressing to allow for Multi-purpose 

Lubricants at VOC content levels of 25 percent and, in the future 10 percent, staff 

intends to work with industry to assess progress as compliance dates near. To that 

end, staff is proposing two technology assessments. To ensure that manufacturers are 

on track, and that technology advances as expected, staff believes that manufacturers 

should demonstrate their progress toward meeting these limits. 

 As proposed in new subsection 94513(f) Multi-purpose Lubricant manufacturers 

would need to supply detailed written updates on their research and development 

efforts undertaken to achieve compliance with the VOC limits. The reports would 

include sales and formulation data for products, as well as detailed information on the 

raw materials evaluated for use, maximum incremental reactivity (MIR) values for any 

VOC or LVP-VOC used or evaluated, the function of the raw material evaluated, testing 

protocols used, the results of the testing, the hardware evaluated, and the cost of 

reformulation efforts. The first report would be due on March 31, 2012, and would 

provide data for the 2011 calendar year. A second report would be due on 

March 31, 2014, and would provide data for the 2013 calendar year. 

 Because our data show compliance can be achieved without the use of 

methylene chloride, perchloroethylene, and trichloroethylene we are proposing to 

prohibit the use of these TACs from the Multi-purpose Lubricant category effective 

December 31, 2010. Methylene chloride and perchloroethylene are exempt VOC 

solvents. Therefore, without the prohibition, their use could increase as products 

reformulate to comply. Trichloroethylene is a VOC, and its use would likely decrease to 
Technical Support Document Chapter VI - 102 

meet the proposed limit. However, other solvents are available that make its use 

unnecessary. Prohibiting these three TACs will lead to approximately 0.01 tons per day 

of toxic compound emission reductions from this category. The health effects 

associated with exposure to perchloroethylene, methylene chloride and 

trichloroethylene, are summarized in Chapter VIII, Environmental Impacts. 

 

Issues:

a. Issue: This limit should be set at 10 percent or lower based on findings in the 

Institute for Research and Technical Assistance (IRTA) lubricant research 

summary. 

Response: ARB staff agrees, but believes that additional time is necessary to 

successfully reformulate complying products. Staff is proposing that Multipurpose Lubricants meet a 10 percent by weight VOC limit effective 

December 31, 2015. We believe that lubricant research conducted by IRTA is 

useful data for manufacturers to evaluate as they develop complying products. 

However, there are some limitations. Staff reviewed the lubricant studies 

conducted by IRTA in 2004 and 2006 (IRTA, 2006; IRTA, 2004). It is unclear 

whether the products tested would work well in various household consumer 

applications. Typical household consumers use multi-purpose lubricants for a 

host of lubrication needs, as well as for penetration, water displacement, and rust 

inhibition. IRTA studies focused on commercial manufacturing and repair 

operations with specific lubricating needs. Additionally, IRTA did not test any 

aerosol lubricant products. Our data show that consumers prefer aerosol 

products for their general lubrication needs. 

b. Issue: We believe it may be technologically and commercially feasible to 

reformulate Multi-Purpose Lubricants to a 25 percent VOC limit by 

December 31, 2014. However, the Automotive Specialty Products Association 

(ASPA) asserts that the ARB must commit to conducting a thorough assessment 

for this product category in 2010, 2012 and 2013 to determine the commercial 

and technological feasibility of the 25 percent VOC limit, if requested by our 

industry. 

Response: Staff agrees in part. We have evaluated technology and are 

proposing that products meet a 25 percent VOC limit by December 31, 2013, and 

a technology-forcing limit of 10 percent by December 31, 2015. We also agree 

that technology reviews are appropriate, and are proposing two as described 

earlier. 

REFERENCES 

1. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

 November, 2004. (ARB, 2004a) 
Technical Support Document Chapter VI - 103 

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

the California Consumer Products Regulation: Midterm Measures I. 

June 6, 1997. (ARB, 1997b) 

3. Institute for Research and Technical Assistance. Assessment, Development and

Demonstration of Alternatives to VOC-emitting Lubricants, Vanishing Oils and

Rust Inhibitors. August, 2006. (IRTA, 2006)

4. Institute for Research and Technical Assistance. Alternatives to VOC Emitting 

Petroleum Based Lubricants and Chlorinated Paraffin Lubricants: Minimizing the 

Health and Environmental Consequences. November, 2004. (IRTA, 2004) 

 

11. Odor Eliminator/Remover

Product Category Description: 

 Odor Eliminator/Remover means a product that is designed or labeled to be 

applied exclusively to hard surfaces to inhibit the ability of soils to create malodors, or 

functions to entrap, encapsulate, neutralize, convert or eliminate malodor molecules. 

Odor Eliminator/Remover does not include products designed or labeled for use in 

cleaning soils from hard surfaces, laundering, softening, de-wrinkling or cleaning 

fabrics, or dishwashing, or products that are defined as Air Freshener, Bathroom and 

Tile Cleaner, Carpet/Upholstery Cleaner, Fabric Refresher, General Purpose Cleaner, 

Toilet/Urinal Care Product, Disinfectant, or Sanitizer. Odor Eliminator/Remover is used 

in household, automotive, institutional and commercial settings to counteract unpleasant 

odors. These products may employ bacterial cultures, enzymes or anti-bacterial 

chemical active ingredients to counteract odor causing substances. Use of Odor 

Eliminator/Remover, Air Fresheners and Fabric Refreshers may result in similar 

outcomes such as freshening air or removing odors. Odor Eliminators/Removers are 

distinguished from Air Fresheners, which are released directly to the air, and Fabric 

Refreshers, which are applied to fabric or other soft surfaces. 

 

 Odor Eliminators/Removers are a previously unregulated category. Table VI-21 

below summarizes the sales and emissions from Odor Eliminator/Remover based on 

the results of ARB’s 2003 Survey (ARB, 2004a). Category sales are 7,034 pounds per 

day, or about 3.5 tons per day, adjusted for complete market coverage and grown by 

population, to 2008. 
Technical Support Document Chapter VI - 104 

Table VI-21 

Odor Eliminator/Remover* 

Product Form

Number of 

Products

2008 

Category Sales 

(lbs/day)**

2008 Adjusted 

VOC Emissions 

(lbs/day)**

Aerosol < 5 *** *** 

Liquid 184 7034 247 

Total > 184 *** *** 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a). 

** Survey data adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions).

*** Data not shown due to confidentiality.

 Estimated VOC emissions (grown, by population, to 2008) are 247 pounds per 

day, or about 0.12 tons per day. Because there were less than five aerosol products 

reported in the survey, the sales data are not shown to protect data confidentiality. The 

sales-weighted average VOC content for liquid products as packaged is 3.5 percent and 

2.2 percent as diluted. 

Product Use and Marketing: 

Odor Eliminator/Remover products are used on hard surfaces in household, 

automotive, institutional, and commercial settings to eliminate, neutralize, remove, 

encapsulate, inhibit, control, destroy and/or counteract odor. The household products 

are generally available through retailers, while the institutional and commercial 

products are sold via wholesalers through distribution channels or direct sales. 

Household Odor Eliminators/Removers are used on hard surfaces to treat 

bathroom and kitchen odors, closets, basements, floor mats, drawers, odors from 

ventilation systems, pet odors, cat litter odors, garbage odors, smoke, and odors 

caused by moisture. These products are generally applied as needed with the user 

controlling the amount of product used (ARB, 2004a). 

Automotive Odor Eliminator/Remover products are used to eliminate musty odors 

due to mildew formation in the persistently damp surfaces of automobile air conditioning 

vents and ducts (ARB, 2004a). 

Odor Eliminators/Removers used on hard surfaces in institutional and 

commercial settings control odors from bathrooms, laundry areas, food preparation 

areas and specific industries such as diaper services (ARB, 2004a). Odor 

Eliminator/Remover products used in commercial settings are used to control garbage 

odors from trash compactors/dumpsters; mold and mildew and waste in bathrooms; 

body odor and mold and mildew in locker rooms; odors in air ducts and pipelines; odors 

in transportation settings such as airplanes and buses and odors in remediation 

services (ARB, 2004a). 
Technical Support Document Chapter VI - 105 

Product Formulation: 

 The VOC content of products in the liquid category ranges from 0 to about 

53 percent by weight as diluted. Fragrance oils constitute from 0 to 53 percent of the 

product’s weight as diluted. They produce the product’s scent. Although fragrance 

oils are VOCs by definition, the Consumer Products Regulation allows an exemption of 

up to two percent by weight of the product, as long as the vapor pressure of the 

fragrance and other functional components of the fragrance are less than 2 millimeters 

mercury (mm Hg) at 20 degrees Celsius. 

Emulsifiers are used in the product formulation to aid the mixing of the fragrance 

oil in the water phase by creating a homogeneous liquid. Because the desired 

emulsions are oil-in-water, surfactants with higher hydrophilic-lipophilic balance 

values are more suitable in oil-in-water formulations. 

Active ingredients include bacterial cultures, enzymes, or chemical agents which 

are used to inactivate odor causing molecules. 

Proposed VOC Limit and Compliance: 

 The proposed VOC limit for liquid Odor Eliminator/Remover is 6 percent by 

weight, effective December 31, 2010. As shown in Table VI-22, using adjusted 2010 

emissions, the proposed limits will result in an estimated emission reduction of 

50 pounds per day, or about 0.03 tons per day. Table VI-22 also shows that 82 percent 

of the market currently complies with the proposed 6 percent VOC limit for liquid Odor 

Eliminator/Remover products. The proposed limit for aerosol Odor Eliminator/Remover 

is 25 percent VOC by weight. The aerosol products reported in the survey comply with 

the 25 percent limit. 

Table VI-22 

Odor Eliminator/Remover Proposal*

Product Form

Proposed 

VOC Limit 

(wt. %)

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emission 

Reductions 

(lbs/day)** 

2010 

Emission 

Reductions 

(lbs/day)+

Aerosol 25 < 5 100 0 0 

Liquid 6 154 82 49 50 

Total ------- > 154 ------- 49 50 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a).

** Emission reductions adjusted for complete market coverage and grown, by population, to 2008 

(see Chapter IV, Emissions).

+ Emission reductions adjusted for complete market coverage and grown, by population, to 2010 

(see Chapter IV, Emissions). 
Technical Support Document Chapter VI - 106 

 Generally, reformulation to the 6 percent VOC level will involve replacing some of 

the VOC solvent and/or fragrance with water keeping the active “odor eliminating” 

ingredient constant, or possibly increasing it as appropriate. 

REFERENCES 

1. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

 November, 2004. (ARB, 2004a) 

12. Penetrant 

Product Category Description: 

 Penetrants are lubricant products designed and labeled primarily to loosen metal 

parts that have bonded together due to rusting, oxidation, or other causes. This 

category does not include Multi-purpose Lubricants that claim to have penetrating 

qualities, but are not labeled primarily to loosen bonded parts. Penetrants that are 

(1) sold exclusively to establishments which manufacture or construct goods or 

commodities, and are (2) labeled “not for retail sale” are also excluded from this 

category. 

 Penetrants were first regulated under “Midterm Measures I” of the Consumer 

Products Regulation approved in July of 1997, and a description of these products is 

also included in the staff report for that rulemaking (ARB, 1997b). At that time, the 

Board adopted a 50 percent by weight VOC limit for these products, which became 

effective on January 1, 2003. 

 Table VI-23 below summarizes the sales and emissions from Penetrants based 

on the results of ARB’s 2003 Survey. The data have been grown to the 2008 calendar 

year. Total category sales are about 2,021 pounds per day. 

Table VI-23 

Penetrant*

Product Form

Number of 

Products

2008 

Category Sales 

(lbs/day)**

2008 Adjusted 

VOC Emissions 

(lbs/day)** 

Aerosol 68 1,709 714 

Liquid 16 312 79 

Total 84 2,021 793 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a); Includes products 

containing chlorinated compounds. 

** Survey data adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions).
Technical Support Document Chapter VI - 107 

 Estimated 2008 VOC emissions for Penetrants are 793 pounds per day, or about 

0.4 tons per day, in California. Table VI-23 shows the Penetrant products separated 

into aerosol and liquid forms, with the aerosol form dominating the market in both sales 

and emissions. According to our data, the sales-weighted average for this category is 

38 percent VOC by weight. 

Product Use and Marketing: 

 Penetrants are used by household, institutional and industrial users to loosen 

immovable parts such as rusted pipe fittings, automotive parts, and nuts and bolts. 

Some product labels instruct the user to tap extremely rusted parts after spraying to set 

up vibrations that assist in the penetration of the product (ARB, 2004a). Some 

Penetrants claim to have lubricating properties and many claim corrosion protection 

(ARB, 2004a). 

 Penetrants are sold in hardware stores, automotive parts stores, by specialty 

retailers, by mass merchandisers, and on the Internet. Penetrants are also sold to 

industrial or institutional users through distributors that serve these customers, or 

directly to large customers. 

Product Formulation: 

 Penetrant formulations are similar to Multi-purpose Lubricants in that they contain 

lubricating oils, solvents, and, in some cases, extreme pressure additives, such as a 

fluoropolymer, or molybdenum disulfide. Penetrants are typically comprised of light 

petroleum oils that vary in range from 10 to 40 percent. Liquefied petroleum gas, 

carbon dioxide, or nitrogen gas act as propellants for the aerosol products. The balance 

of the product formulation is comprised of various hydrocarbon solvents. A few 

Penetrants contain chlorinated solvents, such as methylene chloride, perchloroethylene, 

and trichloroethylene. Some contain synthetic oils; vegetable oils; and others utilize 

water-based formulations (ARB, 2004a). 

 Penetrants contain a balance of solvents and oils in order to achieve both low 

viscosity and low surface tension. According to the 2003 Survey, some of the VOC 

solvents used in Penetrants include various grades of petroleum distillates such as 

kerosene (VOC portion), mineral spirits and trichloroethylene. A variety of LVP-VOC 

solvents used in Penetrants include hydrocarbon solvents and fatty acid methyl esters. 

Water is also used. 

Proposed VOC Limit and Compliance: 

 The proposed VOC limit for Penetrants is 25 percent by weight for both aerosol 

and liquid forms, effective December 31, 2013. As shown in Table VI-24, using 

adjusted 2003 emissions, the proposed limit will result in an estimated emission 

reduction of 305 pounds per day, or about 0.15 tons per day, in 2013. 

 
Technical Support Document Chapter VI - 108 

 Table VI-24 also shows that 14 products, representing about 30 percent of the 

total Penetrant market share, currently comply with the proposed 25 percent VOC limit. 

Only those products complying without the use of methylene chloride, 

perchloroethylene, and trichloroethylene are included in the complying market share 

data. The complying products include both aerosol and liquid Penetrants for household, 

commercial and institutional use. 

Table VI-24 

Penetrant Proposal*

Product Form

Proposed 

VOC Limit 

(wt. %)

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emissions 

Reductions 

(lbs/day)** 

2013 

Emissions 

Reductions 

(lbs/day)+

Aerosol 25 9 28 255 271 

Liquid 25 5 36 32 34 

Total 14 30 287 305 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a). 

** Emission reductions adjusted for complete market coverage and grown, by population, to 2008 

(see Chapter IV, Emissions). 

+ Emission reductions adjusted for complete market coverage and grown, by population, to 2012 

(see Chapter IV, Emissions). 

 Penetrants that already comply with the proposed VOC limit are using a 

combination of LVP-VOC solvents, VOC solvents, oils, and various additives. 

Reformulation options include adding more oil to the formulation; replacing some of the 

VOC solvents with LVP-VOC solvents, or water; and using non-VOC alternatives to 

liquefied gas propellants, such as carbon dioxide. Reformulation may also require use of 

less viscous oils. Different solvents may be used to reduce the overall viscosity of some 

Penetrant formulations. 

 

 Because Penetrants are closely related to Multi-purpose Lubricants in formulation 

and their uses, the VOC limits and effective dates for these two categories have 

historically tracked. For this reason, the reformulation efforts for Penetrants are similar 

to Multi-purpose Lubricants in that research to find the correct balance of oils, solvents 

and additives without sacrificing the products’ penetrating ability will be required. 

Therefore, the proposed effective date for the VOC limit for Penetrants is 

December 31, 2013. 

 While staff believes that technologies are progressing to allow for Penetrant 

products at a VOC content level of 25 percent staff intends to work with industry to 

assess progress as the compliance date nears. To that end, staff is proposing a 

technology assessment. To ensure that manufacturers are on track, and that 

technology advances as expected, staff believes that manufacturers should 

demonstrate their progress toward meeting the limit. 
Technical Support Document Chapter VI - 109 

 As proposed in new subsection 94513(f) Penetrant product manufacturers would 

need to supply detailed written updates on their research and development efforts 

undertaken to achieve compliance with the VOC limits. The reports would include sales 

and formulation data for products, as well as detailed information on the raw materials 

evaluated for use, MIR values for any VOC or LVP-VOC used or evaluated, the function 

of the raw material evaluated, testing protocols used, the results of the testing, the 

hardware evaluated, and the cost of reformulation efforts. The report would be due on 

March 31, 2012, and would provide data for the 2011 calendar year. Should technical 

or commercial issues arise, or if it appears reductions could occur within a shorter 

timeframe, staff would develop appropriate measures to ensure air quality benefits 

occur as soon as possible. 

 Because our data show compliance can be achieved without the use of 

methylene chloride, perchloroethylene, and trichloroethylene, we are proposing to 

prohibit the use of these TACs from the Penetrant category, effective 

December 31, 2010. Methylene chloride and perchloroethylene are exempt VOC 

solvents. Therefore, without the prohibition, their use could increase as products 

reformulate to comply. Trichloroethylene is a VOC, and its use would likely decrease to 

meet the proposed limit. However, other solvents are available that make its use 

unnecessary. Prohibiting these three TACs will lead to approximately 0.01 tons per day 

of toxic compound emission reductions from this category. The health effects 

associated with exposure to perchloroethylene, methylene chloride and 

trichloroethylene, are summarized in Chapter VIII, Environmental Impacts. 

 

 We have received information that suggests usage of non-flammable solvents in 

Penetrants is necessary in situations where Penetrants are used on energized 

equipment, near heat, flame, or other ignition sources. Staff agrees. Applying 

Penetrants to energized equipment may pose a safety risk. However, at the present 

time, use of chlorinated solvents is the only option for these applications. 

 Therefore, because of toxicity concerns, we are proposing to prohibit the use of 

perchloroethylene, methylene chloride, and trichloroethylene in Penetrants. However, 

we believe there is a small niche use for non-flammable products. Therefore, we are 

also proposing that Penetrants labeled as non-flammable and for use on energized 

equipment not be subject to the prohibition. To account for this specialized use, but to 

restrict the use of TACs to the extent possible, we are proposing that to qualify for the 

exemption from the toxic prohibition, Penetrants would have to include on the product’s 

Principal Display Panel: “Non-flammable and only for use where equipment is 

energized.” This proposal is set forth in new section 94509(q) of the Consumer 

Products Regulation. 

Issues:

a. Issue: This limit should be set at 10 percent or lower based on findings in the 

Institute for Research and Technical Assistance (IRTA) lubricant research 

summary.
Technical Support Document Chapter VI - 110 

Response: ARB staff disagrees. Staff reviewed the studies conducted by IRTA 

in 2004 and 2006 (IRTA, 2006; IRTA, 2004). The focus was on lubrication rather 

than penetration, therefore it is unclear whether the products tested would work 

well in various penetrant applications. However, as noted above, we are 

proposing a technology review in 2012 to assess progress and to determine if 

future further VOC reductions are feasible. 

b. Issue: We believe it may be technologically and commercially feasible to 

reformulate Penetrants to a 25 percent VOC limit by December 31, 2014. 

However, Automotive Specialty Products Association (ASPA) asserts that the 

ARB must commit to conducting a thorough assessment for this product category 

in 2010, 2012 and 2013 to determine the commercial and technological feasibility 

of the 25 percent VOC limit, if requested by our industry. 

Response: Staff agrees in part. We have evaluated technology and are 

proposing that products meet the 25 percent VOC limit by December 31, 2013. 

We also agree that a technology review is appropriate, and are proposing one in 

2012 as described earlier. 

REFERENCES 

1. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

 November, 2004. (ARB, 2004a) 

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

the California Consumer Products Regulation: Midterm Measures I. 

June 6, 1997. (ARB, 1997b) 

3. Institute for Research and Technical Assistance. Assessment, Development and 

Demonstration of Alternatives to VOC-emitting Lubricants, Vanishing Oils and 

Rust Inhibitors. August, 2006. (IRTA, 2006)

4. Institute for Research and Technical Assistance. Alternatives to VOC Emitting 

Petroleum Based Lubricants and Chlorinated Paraffin Lubricants: Minimizing the 

Health and Environmental Consequences. November, 2004. (IRTA, 2004) 

13. Personal Fragrance Product (products with 20 percent or less fragrance)

Product Category Description: 

Personal Fragrance Product is currently defined as any product which is applied 

to the human body or clothing for the primary purpose of adding a scent or masking a 

malodor, including cologne, perfume, aftershave, and toilet water. Personal Fragrance 

Product does not include: (A) Deodorant, as defined in section 94501(d); 
Technical Support Document Chapter VI - 111 

(B) medicated products designed primarily to alleviate fungal or bacterial growth 

on feet or other areas of the body; (C) mouthwashes, breath fresheners and 

deodorizers; (D) lotions, moisturizers, powders or other skin care products used 

primarily to alleviate skin conditions such as dryness and irritations; (E) products 

designed exclusively for use on human genitalia; (F) soaps, shampoos, and products 

primarily used to clean the human body; and (G) fragrance products designed to be 

used exclusively on non-human animals. 

Staff is proposing to add clarifying language to the definition to indicate that 

Personal Fragrance Product includes, but is not limited to, lotions, powders, body mists, 

and body sprays. 

 Personal Fragrance Products were regulated under “Phase II” of the Consumer 

Products Regulation adopted in January of 1992, and a description of these products is 

also included in the staff report for that rulemaking (ARB, 1991a). However, instead of 

the product forms and standards described in that staff report, the Board divided the 

category into two subcategories, based on fragrance content, and adopted two tiers of 

VOC limits for each subcategory. Products with 20 percent or less fragrance were 

required to meet a VOC limit of 80 percent by weight, effective in 1995. A future lower 

limit of 75 percent by weight became effective in 1999. Products with more than 

20 percent fragrance were required to meet a VOC limit of 70 percent by weight, 

effective in 1995. A lower limit of 65 percent became effective in 1999 (ARB, 1992). 

 However, an exemption from compliance with the initial VOC limit was adopted 

for existing products, and products “in development” on or before April 1, 1992, provided 

that such products were registered with ARB prior to July 1, 1993, and were sold in 

California before January 1, 1994. The regulation was further amended to specify 

(section 94510(l)) that the January 1, 1999 VOC limits do not apply to products which 

were sold in California prior to January 1, 1999 (ARB, 2007a). The overall effect of 

these two exemptions (“Grandfather” clauses) has meant that products in existence 

prior to 1992 were not reformulated to comply with VOC limits, and products subject to 

the 1995 first tier limit did not have to reformulate to meet the second tier 1999 VOC 

limits. Only products introduced after 1999 have been required to meet the second tier 

limits (ARB, 1992). 

In addition, section 94510(j) of the Consumer Product Regulation specifies that the 

VOC standards specified in section 94509(a) do not apply to any VOC which is a 

fragrance in a Personal Fragrance Product (ARB, 2007a). 

 The Personal Fragrance Product category (products with 20 percent or less 

fragrance) is one of the larger emissions sources within the personal fragrance 

category. The proposal for this rulemaking affects only those Personal Fragrance 

Products with 20 percent or less fragrance. Table VI-25 below summarizes the sales 

and emissions from Personal Fragrance Products with 20 percent or less fragrance, 

based on the results of ARB’s 2003 Survey (ARB, 2004a). The data have been grown 

to the 2008 calendar year. Total category sales are about 26,905 pounds per day. 
Technical Support Document Chapter VI - 112 

Table VI-25 

Personal Fragrance Product (products with 20 percent or less fragrance)* 

Product Form

Number of 

Products

2008 

Category Sales 

(lbs/day)**

2008 Adjusted 

VOC Emissions 

(lbs/day)**

All Forms 1101 26,905 21,809 

* Based on 2003 Consumer and Commercial Products Survey. (ARB, 2004a)

** Survey data adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions). 

 

 This category includes all product forms and includes, but is not limited to, 

colognes, perfumes, aftershaves, toilet waters, lotions, powders, body mists, and body 

sprays. Personal Fragrance Product (products with 20 percent or less fragrance) have 

estimated VOC emissions of 21,809 pounds per day , or about 10.9 tons per day, in 

California. Although not shown in Table VI-25, the sales-weighted average VOC 

content for this category is about 81 percent by weight including fragrance and about 

76 percent by weight excluding fragrance. 

Product Use and Marketing:

Personal Fragrance Products (products with 20 percent or less fragrance) are 

used by both men and women to impart a fragrance or scent. The concentration of 

fragrance oil found in different products can vary widely. Perfumes, toilet waters, 

colognes, and aftershaves make up the largest segment of the personal fragrance 

market. Perfumes, colognes, and toilet waters are generally more concentrated in 

fragrance, than body sprays or aftershaves, and are used in smaller quantities. In 

general, perfumes are the most expensive and concentrated, followed by toilet waters 

(or eau de toilettes), and colognes (or eau de colognes) (ARB, 1991a). Perfumes are 

typically used in small quantities and are intended for “spot” or “pulse point” application. 

Colognes and toilet waters are the most common fragrance form and are intended for 

“everyday” use (ARB, 1991a). These products are typically less concentrated and are 

used more liberally. 

Personal Fragrance Products are typically sold in retail stores, department 

stores, and diversified drug stores, but are also available to consumers for purchase 

from discount warehouses, Internet companies, home sales, and catalog sales. It is 

estimated that sales of women’s fragrances are approximately twice as much as sales 

of men’s fragrance products (PCPC, 2006). 
Technical Support Document Chapter VI - 113 

Product Formulation: 

 The main ingredients found in Personal Fragrance Products (products with 

20 percent or less fragrance) are denatured alcohol (ethanol), fragrances, and water. 

Aerosol products also contain VOC propellants such as n-Butane, propane, isobutane, 

and/or the non-VOC propellant, HFC-152a. It should be noted that denatured alcohol 

often contains 5 to 7 percent water and that any VOC which is a fragrance in a Personal 

Fragrance Product is exempt from the VOC limits. Ethanol is the primary VOC 

ingredient in this category and is most likely to be the VOC ingredient that is reduced in 

the reformulation of a product. 

The majority of Personal Fragrance Products (products with 20 percent or less 

fragrance) contain fragrance oil dissolved in ethanol and, to a lesser degree, water. 

Small amounts of other ingredients may also be included, such as preservatives, 

colorants, and agents used to prevent photodegradation or oxidation of fragrance 

ingredients (ARB, 1991a). 

Proposed VOC Limit and Compliance: 

Staff is not proposing to lower existing VOC limits for Personal Fragrance Product 

(products with 20 percent or less fragrance), but instead is proposing to eliminate the 

“Grandfather” clauses for this category. This would require that all products, new and 

existing, be subject to the same VOC standard, namely 75 percent by weight. 

Based on the 2003 Survey, products within a signature line contain varying 

amounts of ethanol and fragrance, but continue to be labeled and sold under the same 

signature line as the same scent (ARB, 2004a). This is an indication that reformulation 

is possible, while preserving a signature scent. Companies with products covered 

under the “Grandfather” clauses may have been operating with a competitive advantage 

since 1995, having avoided the cost of reformulation, consumer testing, and marketing. 

This proposal will require companies to reformulate their products to meet the 

75 percent by weight VOC limit, regardless of when they were first sold in California. 

As shown in Table V-26 below, 679 products comply with the 75 percent by weight 

VOC standard; indicating that products can be reformulated to comply with the 

standard. The complying products account for about 37 percent of the market. 

 

 Removing the “Grandfather” clauses will result in an estimated emission 

reduction of 824 pounds per day, or 0.41 tons per day, using emissions adjusted to 

2014. If adopted, the removal of the “Grandfather” clauses would become effective 

December 31, 2014. We are proposing to extend the effective date until 

December 31, 2014 because of the large number of products that would need to be 

reformulated. 
Technical Support Document Chapter VI - 114 

Table VI-26 

Personal Fragrance Product (products with 20 percent or less fragrance) 

Proposal* 

Product 

Form

Proposed VOC 

Limit (wt. %)

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emission 

Reductions 

(lbs/day)** 

2014 

Emission 

Reductions 

(lbs/day)+

All Forms 

75 (Remove 

“Grandfather” 

clauses) 

679 37 765 824 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a). 

** Emission reductions adjusted for complete market coverage and grown, by population, to 2008 

(see Chapter IV, Emissions).

+ Emission reductions adjusted for complete market coverage and grown, by population, to 2014 

(see Chapter IV, Emissions).

Compliance with the Standard:

Removing the exemption for existing products will subject both new and existing 

Personal Fragrance Products (products with 20 percent or less fragrance) to a 

75 percent by weight VOC standard. Reformulation options could include reducing 

ethanol content, adding water, making adjustments to fragrance components that can 

tolerate higher levels of water, and, if applicable, replacing VOC propellants with nonVOC propellants. 

The most straightforward method of reformulating Personal Fragrance Products 

(products with 20 percent or less fragrance) is to replace some of the alcohol with water 

or some other non-VOC ingredients. Simple replacement, as industry has pointed out, 

may lead to an altered fragrance due to some of the fragrance oil ingredients "coming 

out of solution." However, emulsion technology or fragrance modification may be 

utilized to minimize fragrance alteration (ARB, 1991a). 

Reformulation options also include adjustments to the fragrance oil components 

to allow for higher water content. For example, fractional distillation of the polar 

compounds, in some essential oils, would yield water-soluble extracts retaining the 

same fragrance as their essential oil even though they may differ greatly in chemical 

nature. Examples would include the distilled aromatic waters from rose, witch hazel, 

yarrow, orange flowers, chamomile, balm mint and linden (ARB, 1991a). One study 

reported that by lowering the quantities of crystalline materials such as vanillin, 

coumarin, and heliotropin and using resins such as oak moss and Mousse de Chene 

sparingly, fragrance solubility in aerosol products can be increased (ARB, 1991a). 

Another reformulation option for aerosol products could include adjusting 

propellant. For example, the amount of VOC propellant could be adjusted or VOC 

propellant could be blended with non-VOC propellant, such as HFC-152a. However, we 

do not expect such propellant blending to occur as the limit is feasible without the use of 

HFC-152a, a more expensive propellant. Although hydrocarbon propellants function 
Technical Support Document Chapter VI - 115 

also as solvents in aerosol formulations, they are poor solvents for some fragrance 

constituents. According to an article in "Cosmetics and Toiletries," hydrocarbon 

propellants are poor solvents for many of the polar constituents of perfume oils (ARB, 

1991a). We conclude, for the reasons given, above, that it is unlikely propellant 

adjustments will result in fragrance alterations. 

Issues: 

a. Issue: Reducing the alcohol content of personal fragrance products will result in 

some fragrance components precipitating out of solution, resulting in an altered 

fragrance. 

Response: While simple replacement of alcohol with water may result in some 

fragrance components precipitating out, emulsifying agents may be used to 

prevent this. In addition, certain fragrance oil components are more compatible 

with water. By properly selecting the components from these fragrance oils, a 

formulator can create a scent that can tolerate high levels of water. According to 

the 1991 and 2003 ARB Consumer Products Surveys, many aftershave products 

with water content ranging from 10 to 90 percent have been identified. Colognes 

with 1 to 90 percent water content and perfumes with zero to 10 percent water 

content have also been identified. 

b. Issue: The proposed VOC restrictions will hinder the creative process of 

developing a fragrance by limiting the choice of fragrance oils. 

Response: According to the 2003 Survey, there are over 670 products that 

comply with the existing 75 percent by weight VOC limit. ARB staff has identified 

complying colognes and perfumes from a number of the fragrance families, 

including, but not limited to the following: musk, floral, chypre, aldehydic, 

tobacco and leather, spicy, and oriental. This indicates that manufacturers 

will not be limited to a narrow range of scent types. In addition, the staff 

has identified a number of technologies that can be used to comply with the VOC 

standards in the regulation without necessarily limiting manufacturers to fewer 

fragrance oils. We are confident the creative abilities of perfumers and 

manufacturers will allow development of products that meet consumers’ needs 

and reduce VOC emissions. 

c. Issue: The Personal Care Products Council has provided ARB staff with a twotiered proposal for consideration. Products between 75 to 80 percent by weight 

VOC would be subject to a VOC limit of 75 percent by weight. Products above 

80 percent by weight VOC would be reformulated to a VOC limit of 80 percent by 

weight. In addition, industry requests a lengthier compliance period of 5 years. 

Response: Companies with products covered under the “Grandfather” clauses 

may have been operating with a competitive advantage since 1995, when the 

first-tier VOC limit of 80 percent by weight became effective. In order to level the 
Technical Support Document Chapter VI - 116 

playing field for all stakeholders, staff is proposing a single VOC standard. 

However, staff is proposing an extended future effective date of 

December 31, 2014, to provide sufficient time for companies to reformulate and 

conduct consumer testing of the hundreds of currently “grandfathered” products. 

REFERENCES 

1. Air Resources Board. The California Consumer Products Regulations. 

December, 2007. (ARB, 2007a) 

2. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

 November, 2004. (ARB, 2004a) 

3. Air Resources Board. Final Statement of Reasons for Rulemaking, Public 

Hearing to Consider the Adoption of Amendments to the Regulation for Reducing 

Volatile Organic Compound Emissions from Consumer Products - Phase II. 

January 9, 1992. (ARB, 1992) 

4. Air Resources Board. Proposed Amendments to the Statewide Regulation to 

Reduce Volatile Organic Compound Emissions from Consumer Products - Phase 

II – Technical Support Document. October, 1991. (ARB, 1991a) 

5. Personal Care Products Council (formerly known as Cosmetic, Toiletry and 

Fragrance Association). Presentation to ARB staff. July 26, 2006. 

 (PCPC, 2006) 

14. Sealant or Caulking Compound 

Product Category Description:

Sealant or Caulking Compound is any product with adhesive properties that is 

designed to fill, seal, waterproof, or weatherproof gaps or joints between two surfaces, 

including threaded pipe sealants and gasket makers. Sealant or Caulking Compound 

does not include roof cements and roof sealants; insulating foams; removable caulking 

compounds; clear/paintable/water resistant caulking compounds; floor seam sealers; 

products designed exclusively for automotive uses; or sealers that are applied as 

continuous coatings. Sealant or Caulking Compound also does not include units of 

product, less packaging, which weigh more than one pound and consist of more than 

16 fluid ounces. 

“Removable caulking compounds” means a compound which temporarily seals 

windows or doors for three to six month time intervals. “Clear/paintable/water resistant 

compounds” means a compound which contains no appreciable level of opaque fillers 

or pigments; transmits most or all visible light through the caulk when cured; is 

paintable; and is immediately resistant to precipitation upon application. 
Technical Support Document Chapter VI - 117 

Sealant and caulking products, packaged in aerosol and non-aerosol forms, were 

first regulated statewide under the “Midterm Measures II” of the Consumer Products 

Regulation, adopted in October of 1999, and a description of these products is also 

included in the staff report for that rulemaking (ARB, 1999). At that time, the Board 

adopted a single VOC limit of 4 percent by weight for all forms of these products, which 

became effective on December 31, 2002. We believe technology now exists to further 

reduce the VOC content limit for non-aerosol Sealant or Caulking Compound products. 

For this current rulemaking, staff is proposing to change the category name from 

Sealant and Caulking Compound to Sealant or Caulking Compound. In addition, staff 

has proposed to subcategorize the category into Non-Chemically Curing Sealant or 

Caulking Compound and Chemically Curing Sealant or Caulking Compound with 

different proposed VOC limits for non-aerosol products in these two subcategories. 

Other minor clarifications in the definition are also proposed, such as clarifying that the 

Sealant or Caulking Compound definition includes threaded pipe sealants and gasket 

makers. 

 We are proposing to divide the non-aerosol products into two subcategories 

based on the formulation technologies used. A Chemically Curing Sealant or Caulking 

Compound is defined as any Sealant or Caulking Compound which achieves its final 

composition and physical form through a catalyst-driven chemical reaction. The 

reaction causes a change in chemical structure, and leads to the release of chemical 

by-products. Chemically Curing Sealant or Caulking Compound includes, but is not 

limited to products that utilize silicone, polyurethane, silyl-terminated polyether or silylterminated polyurethane reactive chemistries. Chemically Curing Sealant or Caulking 

Compound does not include products, which are not solely dependent on a chemically 

curing process to achieve the cured state. Non-Chemically Curing Sealant or Caulking 

Compound means any Sealant or Caulking Compound which is not a Chemically Curing 

Sealant or Caulking Compound. 

Staff is proposing to add clarifying language that the Sealant or Caulking 

Compound definition includes pipe thread sealants and gasket makers as these 

products are designed to fill, seal, waterproof or weatherproof gaps or joints between 

two surfaces. Staff has made a number of product reviews, at the request of 

manufacturers, and determined that such products are subject to the Consumer 

Products Regulation requirements for Sealant or Caulking Compounds. 

While Sealant or Caulking Compound products come in several forms, ten to 

eleven fluid ounce disposable cartridges that fit in half-barrel caulking guns are the most 

common. Smaller squeeze tubes are also available. Sealant or Caulking Compound 

products vary in their ability to adhere to different materials and in their resilience, 

durability, cost, and ease of clean-up. Some products have special properties, such as 

mildew resistance, high flexibility, temperature resistance, abrasion resistance, 

paintability, and the ability to self-level.
Technical Support Document Chapter VI - 118 

 By definition, the proposal affects products that consist of 16 fluid ounces or less 

and weigh one pound or less. The local air districts in California regulate the use of 

large size (greater than 16 fluid ounces or one pound) and industrial-use sealants and 

caulks. Following is a list of local air districts and their corresponding currently 

applicable Sealant or Caulking Compound regulations: 

• Bay Area AQMD, Rule 8-51, Adhesives and Sealant Products; 

• Sacramento Metropolitan AQMD, Rule 460, Adhesives and Sealants; 

• Santa Barbara County APCD, Rule 353, Adhesives and Sealants; 

• Shasta County APCD, Rule 3-32, Adhesives and Sealants; 

• South Coast AQMD, Rule 1168, Adhesive and Sealant Applications; 

• Tehama County APCD, Rule 4-40, Adhesives and Sealants; and 

• Ventura County APCD, Rule 74.20, Adhesives and Sealants. 

 Table VI-27 summarizes the sales and emissions from Sealant or Caulking 

Compound products based on the results of ARB’s 2003 Survey (ARB, 2004a). The 

data have been grown to the 2008 calendar year. Total category sales are about 

141,927 pounds per day. 

Estimated combined VOC emissions from the non-aerosol Sealant or Caulking 

Compound category are 5,168 pounds per day, or about 2.6 tons per day, in California. 

Although not shown in Table VI-27, the sales-weighted average VOC content was about 

2 percent by weight for the non-aerosol products in the Non-Chemically Curing Sealant 

or Caulking Compound subcategory, and about 7 percent by weight for the non-aerosol 

products in the Chemically Curing Sealant or Caulking Compound subcategory, 

according to the 2003 Survey. The sales-weighted average VOC content values for the 

two subcategories were based on the group of products that also included sell-through 

products with VOC content above the current VOC limit of 4 percent for the category. 

Due to the impact of sell-through products with higher VOC content, the calculated 

values for the sales-weighted average are greater than what they would be with all 

products reformulated to meet the current VOC limit. 

Product Use and Marketing: 

Non-aerosol Sealant or Caulking Compound products are used to prevent air 

infiltration, heat loss, water penetration, insect entry, or to improve appearance while 

being flexible and resistant to substrate movement. These products are also used to 

prevent the passage of a liquid or gas between two surfaces, while being flexible and 

resistant to substrate movement. 

 Non-aerosol Sealant or Caulking Compound products are used extensively in the 

construction, remodeling, and maintenance of houses and other structures in order to 

further weatherize and protect the structure. There are many different types and uses 

for sealants and caulks, including: exterior sealants and caulks; all-purpose 

indoor/outdoor sealant and caulks; removable sealant and caulks; roof repair sealants 
Technical Support Document Chapter VI - 119 

Table VI-27 

Sealant or Caulking Compound (non-aerosol)* 

Product Subcategory

Number of 

Products

2008 Category 

Sales (lbs/day)**

2008 Adjusted 

VOC Emissions 

(lbs/day)**

Non-Chemically Curing 

Sealant or Caulking 

Compound (non-aerosol) 

344 83,915 1,354 

Chemically Curing Sealant 

or Caulking Compound 

(non-aerosol) 

196 58,012 3,814 

Total 540 141,927 5,168 

* Based on 2003 Consumer and Commercial Products Survey. (ARB, 2004a)

** Survey data adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions).

and caulks; elastomeric sealant and caulks; high temperature sealants and caulks; 

waterproof (submerged) sealant and caulks; gasket makers; and pipe thread sealants. 

These products are used for filling gaps and cracks in a foundation; around windows 

and doors; vents; faucets; pipes; wiring; electrical and utility boxes; outlets; ceiling 

fixtures; drains; bathtubs; tiles; air conditioners; ceiling and wall joints; chimneys; and 

other uses. 

 The market offers Chemically Curing Sealant or Caulking Compound products 

and Non-Chemically Curing Sealant or Caulking Compound products. Chemically 

curing products undergo a chemical reaction in the presence of a catalyst leading to a 

change in chemical structure, such as cross-linking of a polymer, as part of the curing 

process. Non-chemically curing products do not participate in such chemical reactions. 

The curing actually occurs through a physical change by water or solvent evaporation. 

Non-Chemically Curing Sealant or Caulking Compound (non-aerosol): 

Non-Chemically Curing Sealant or Caulking Compound non-aerosol products do 

not cure through a chemical reaction. The curing results from solvent evaporation. 

Some of the basic types of sealants and caulks on the market today include acrylic latex 

caulks, solvent-based synthetic rubber products, butyl caulks, and oil-based sealants 

and caulks. Some non-chemically curing sealants and caulks use the terms 

“siliconized” or “polyurethane acrylic product” but they do not chemically cure. 

Acrylic latex caulks are often chosen for general use because of their low price, 

durability, convenience, low odor, low toxicity, and effectiveness on both inside and 

outside surfaces. These compounds remain durable and flexible after they have been 

applied, and are not affected by the sun’s ultraviolet (UV) rays, alkali surfaces, or water. 

According to product labels, acrylic latex sealants will also adhere well to concrete, 

ceramic tile, paint, wood, sheet rock, plaster, bricks, plastic, and glass. However, they 
Technical Support Document Chapter VI - 120 

are not recommended for use in extreme temperatures, continuously damp areas, or for 

high-movement areas (ARB, 1999). 

Siliconized latex caulks have some of the performance characteristics of siliconebased chemically curing caulks. Silicone is added to latex for increased durability, 

better adhesion, and increased flexibility. Application is easy, clean-up is with water, 

and the cost is lower than pure silicone caulks. This caulk is paintable and comes in a 

variety of colors. Cure time is between 12-24 hours and the caulk should not be 

exposed to water in this period of time (ARB, 1999). 

Solvent-based synthetic rubber sealants and caulks also claim to adhere well to 

most surfaces and can be applied under harsh weather conditions. They have an ability 

to recover, stretch and are paintable with water-based paints. These products are more 

prone to shrinkage and are flammable until they cure. They are also higher in VOC 

content (Pontolilo, 2004). 

Butyl caulks are used to seal exterior metal and masonry surfaces. They are 

solvent-based with a life expectancy of 2 to 5 years. Although butyl caulks can be 

painted, they usually take 3 to 7 days to dry. Purported advantages of butyl caulks 

include their relatively low cost, good water resistance, and good adhesion without 

primers. Disadvantages may include limited joint movement tolerance, a tendency for 

shrinkage, and difficulty in forming a neat bead. However, butyl caulks will not become 

brittle and have good resiliency. Clean up can be difficult because they require special 

chemical solutions (ARB, 1999). 

Oil-based sealants and caulks are usually inexpensive, low durability caulks 

composed of drying oils, such as linseed oil, and fillers. The oils slowly dry out and the 

caulk could show significant hardening and cracking within a year. They also can 

discolor and stain the surface to which they are applied when the surface is not primed 

(ARB, 1999).

Chemically Curing Sealant or Caulking Compound (non-aerosol): 

 

 Chemically Curing Sealant or Caulking Compound non-aerosol products include, 

but are not limited to, products that utilize silicone, polyurethane, silyl-terminated 

polyether and silyl-terminated polyurethane reactive chemistries. Products based on 

these reactive chemistries cure by absorbing atmospheric moisture. 

Products with silicone chemical cure have a wide variety of performance 

characteristics. Silicone sealants and caulks have very little shrinkage, high flexibility, 

and are available both in clear and pigmented formula. According to manufacturers, 

these products are chosen by many consumers for their long term durability and UV 

resistance. As stated on product labels, silicone sealants and caulks are good for joints 

that move extensively, will perform at very low and high temperatures, and have a fast 

cure rate. These products are formulated for most substrates and are claimed to be 

good for adhesion to nonporous surfaces, such as glass, metal, ceramic tile and 
Technical Support Document Chapter VI - 121 

porcelain. However, most silicone-based compounds cannot be painted and tear easily 

(Pontolilo, 2004). 

Products utilizing polyurethane chemical cure claim to have versatile properties 

and are used in a wide range of commercial applications. Product labels indicate that 

they are flexible, can be painted and can adhere to most surfaces. In addition, these 

products have good chemical resistance. Consumers have a choice of non-sagging or 

self-leveling formulas (HPI, 2008). Polyurethanes are able to fill larger cracks because 

they expand when curing and can act as both an insulation and air barrier. However, 

polyurethanes must be protected from UV radiation (ARB, 1999). 

Modified silicone polymer sealants are relatively new products that offer the 

benefits of water-based, silicone and polyurethane sealants. These products are also 

more expensive. According to product labels, modified silicone polymer sealants and 

caulks can be applied in extreme temperatures, are watertight almost immediately, are 

very durable and adhere well to most substrate materials. Modified silicone polymers 

include silyl-terminated polyether products. These products claim to be flexible, 

paintable, quick curing and do not shrink. They are also low in VOC content (Pontolilo, 

2004). Silyl-terminated polyurethane products are purported to have several distinct 

advantages over conventional polyurethanes. These products show improved adhesion 

to glass, UV stability and weatherability (O’Connor, 2004). 

Sealants and caulks are sold in hardware stores, home supply stores, paint 

stores, hobby and craft stores, and by mass merchandisers. Sealants are also sold to 

industrial or institutional users through distributors or through direct sales by the 

manufacturer.

Product Formulation: 

 Sealant or Caulking Compound products generally have low solvent levels, high 

concentrations of fillers, and are thick and nonpourable. 

Non-Chemically Curing Sealant or Caulking Compound (non-aerosol): 

Non-Chemically Curing Sealant or Caulking Compound non-aerosol products are 

either water-based or solvent-based. One of the advantages of water-based caulking 

compounds is that they can be cleaned up with water prior to curing. Solvent-based 

compounds must be cleaned up with solvents. Each type of sealant or caulking 

compound formulation offers its own particular strength and weakness depending on 

how it is used. Many products are formulated to meet the performance requirements 

described in American Society for Testing and Materials (ASTM) C-920, the “Standard 

Specification for Elastomeric Joint Sealants.” 

A typical formulation might consist of the following: 

1. Polymer – Polymer is the most important contributing factor to sealant or caulk 

performance. It provides elastomeric and adhesive properties. Different types of resins 
Technical Support Document Chapter VI - 122 

include oil-based, butyl, solvent-based acrylic, block copolymer, polyvinyl acetate and 

water-based acrylic polymers (ARB, 1999). 

2. Plasticizer – Plasticizers improve sealant flexibility, extrudability of uncured product, 

and can reduce cost. The plasticizer must be compatible with the polymer system being 

used. As the plasticizer content increases, adhesion decreases. Types of plasticizers 

include phthalates, benzoate, and epoxidized oils (ARB, 1999). 

3. Filler – Fillers provide reinforcement to the product, can reduce product raw material 

cost, add desired color to the product, and can impart sag or slump resistance. Types 

of fillers include calcium carbonate (chalk), aluminum silicate (clay), magnesium silicate 

(talc), fumed silica, cellulosic fiber, organic clays, titanium dioxide, carbon blacks, and 

metal oxides (ARB, 1999). 

4. Specialty Additives – Additives are used to improve and enhance specific aspects 

of the sealant or caulk such as weatherability, adhesion, package stability, and cure 

rate. Examples of specialty additives are adhesion promoters, UV absorbers, biocides, 

pigments, and waterborne additives. Adhesion promoters, such as organotitanates and 

silane coupling agents, provide adhesion to specific substrates. UV absorbers, which 

include hindered amines and benzotriazoles, provide long term stability of the cured 

product and eliminate surface cracking, chalking, or discoloration. Finally, waterborne 

additives, such as freeze thaw stabilizers, are used to preserve the integrity of latex 

particles. Examples of common waterborne additives are: ethylene glycol, propylene 

glycol, urea, and isopropanol (ARB, 1999). Biocides are added to provide antimicrobial 

protection, which is especially important in sealants or caulks used in the kitchen and 

bathroom, where water and mildew are common (Pontolilo, 2004). 

5. Diluents – Diluents reduce the viscosity and aid in the application of the sealant or 

caulk. For water-based formulations, water is the primary diluent, however, some VOC 

co-solvents are used including: acetates (acetic acid, butyl acetate, vinyl acetate, etc.), 

alcohols (ethanol, methanol, isopropanol, etc.), and glycols (ethylene glycol, propylene 

glycol, diethylene glycol methyl ether, etc.). Diluents used in solvent-based formulations 

include: mineral spirits, hexane, stoddard solvent, toluene, and xylene. Manufacturers 

limit the amount of diluents to control shrinkage resulting from the evaporation of the 

diluent during curing (ARB, 1999). A few products reported in the 2003 Survey contain 

perchloroethylene, an exempt VOC solvent. 

Chemically Curing Sealant or Caulking Compound (non-aerosol): 

Chemically Curing Sealant or Caulking Compound non-aerosol products 

participate in a chemical reaction. The reaction usually involves the formation of new 

internal bonds and results in a change in the chemical structure of the product, such as 

cross-linking of a polymer. As compounds undergo cross-linking reactions as part of 

the curing process, products become more stable and chemical by-products are 

released. 
Technical Support Document Chapter VI - 123 

 Chemically curing products that utilize silicone, polyurethane, or modified silicone 

polyether reactive chemistries react in the presence of moisture. Similar to 

non-chemically curing products, chemically curing products also contain fillers, 

polymers, plasticizers and specialty additives. These products also contain catalysts 

and cross-linkers. Catalysts are used to initiate the reaction, and examples include 

peroxides, tertiary amines, and compounds based on nickel, tin, or platinum (ARB, 

1999). Cross-linkers are involved in the actual cross-linking once the cure reaction is 

initiated. 

 Silicone sealants contain siloxane polymers and plasticizers. Most of these are 

based on polydimethylsiloxane. Depending on whether the formula is based on an 

acetoxy, neutral or basic cure type, cross-linkers involved can be acetoxy, oxime or 

alcohol. Consequently, groups released during the reaction would include an acetic 

acid, an oxime, such as 2-oximobutane, or amine, such as cyclohexylamine, depending 

on the cure type (Macco, 2006). 

 Polyurethane cure reaction is based on the cross-linking of isocyanates and an 

alcohol (polyol) during cure. Some common isocyanates used in a formula include 

toluene diisocyanate, isophorone diisocyanate and hexamethylene diisocyanate 

(Macco, 2006). 

 Products that are based on silyl-terminated polyethers are very similar to silicone 

sealants and caulks with acidic cure. They differ in the types of cross-linker functional 

groups, leading to the release of an alcohol during the reaction, such as methanol, 

ethanol or propanol, instead of an acid (Macco, 2006). Silyl-terminated polyurethanes 

contain urethane prepolymers, prepared from the reaction of a diisocyante and a 

conventional polyol, that are end-capped with an organo-functional silane. Silylterminated polyurethane sealants have been prepared with varying isocyanates, polyol, 

and silanes (O’Connor, 2004). 

Proposed VOC Limit and Compliance: 

 The proposed VOC limit for the Non-Chemically Curing Sealant or Caulking 

Compound non-aerosol subcategory is 1.5 percent by weight, effective 

December 31, 2010. The proposed VOC limit for the Chemically Curing Sealant or 

Caulking Compound non-aerosol subcategory is 3 percent by weight, effective 

December 31, 2012. 

 As shown in Table VI-28a, using emissions adjusted to 2010, the proposed limit 

will result in an estimated emission reduction of 246 pounds per day, or about 

0.12 tons per day, for the Non-Chemically Curing Sealant or Caulking Compound nonaerosol subcategory. 
Technical Support Document Chapter VI - 124 

Table VI-28a 

Non-Chemically Curing Sealant or Caulking Compound (non-aerosol) 

Subcategory Proposal) 

Product Form

Proposed 

VOC Limit 

(wt. %)

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emission 

Reductions 

(lbs/day)** 

2010 

Emission 

Reductions 

(lbs/day)+

Non-aerosol 1.5 201 76 240 246 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a). 

** Emission reductions adjusted for complete market coverage and grown, by population, to 2008 

(see Chapter IV, Emissions).

+ Emission reductions adjusted for complete market coverage and grown, by population, to 2010 

(see Chapter IV, Emissions).

 Complying products in the Non-Chemically Curing Sealant or Caulking 

Compound non-aerosol subcategory include water-based and solvent-based 

technologies. Only those products complying without the use of perchloroethylene are 

included in the complying market share data. Most of the complying products are 

water-based formulations. Reformulation options include switching from solvent-based 

formulations to water-based formulations, using alternative LVP-VOC solvents or a 

combination of VOC and LVP- VOC solvents. These alternative ingredients are already 

being used in many products. 

 As shown in Table VI-28b, using emissions adjusted to 2012, the proposed limit 

will result in an estimated emission reduction of 446 pounds per day, or about 

0.22 tons per day, for the Chemically Curing Sealant or Caulking Compound nonaerosol subcategory. 

Table VI-28b 

Chemically Curing Sealant or Caulking Compound (non-aerosol) Subcategory 

Proposal*

Product Form

Proposed 

VOC Limit 

(wt. %)

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emission 

Reductions 

(lbs/day)** 

2012 

Emission 

Reductions 

(lbs/day)+

Non-aerosol 3 95 23 420 446 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a).

** Emission reductions adjusted for complete market coverage and grown, by population, to 2008 

(see Chapter IV, Emissions).

+ Emission reductions adjusted for complete market coverage and grown, by population, to 2012 

(see Chapter IV, Emissions).

 Non-complying products in the Chemically Curing Sealant or Caulking 

Compound non-aerosol subcategory may reformulate by lowering the amount of VOC 

solvents, using alternative LVP-VOC solvents or a combination of both. Where the 

essential formulation components involved in the chemical cure reaction contribute to 
Technical Support Document Chapter VI - 125 

VOC content themselves or lead to the formation and release of VOC compounds as 

by-products of the cure, products may reformulate by slightly reducing the levels of VOC 

cross-linkers or other VOC ingredients and increasing the levels of non-VOC 

ingredients, such as fillers, non-VOC polymers and resins, and other additives. 

 In some cases, reformulation efforts will involve modification of the existing 

resins/polymers or development of new resins for some of the reactive chemistries. 

Currently, the market resin supply is somewhat uncertain. Resins are not developed 

specifically for sealants and caulks because it is a small market. Hence, manufacturers 

have to select from those available and test different resins and combinations. Because 

of this, staff believes an extended effective date is warranted. The Chemically Curing 

Sealant or Caulking Compound non-aerosol subcategory would be given until 

December 31, 2012, to comply with the proposed VOC limit. This extra time should 

give manufacturers the time required for research and development efforts to work with 

resin and polymer reactive chemistry systems to develop a complying formula. 

 Staff is also proposing in section 92412(d) additional labeling requirements for 

non-aerosol Sealant or Caulking Compound. The product category as specified in 

section 94509(a), or an abbreviation of the category, and the applicable VOC standard 

shall be displayed. This requirement is to facilitate enforcement of the applicable 

standards for Chemically Curing and Non-Chemically Curing products. 

 Aerosol Sealant or Caulking Compound products continue to be subject to the 

4 percent VOC by weight limit, effective December 31, 2002. Our data show that there 

are existing compliant Chemically Curing and Non-Chemically Curing aerosol products. 

 Because our data for both aerosol and non-aerosol products show compliance 

can be achieved without the use of methylene chloride, perchloroethylene, and 

trichloroethylene, we are proposing to prohibit the use of these TACs from the Sealant 

or Caulking Compound category, effective December 31, 2010. Methylene chloride and 

perchloroethylene are exempt VOC solvents. Therefore, without the prohibition, their 

use could increase as products reformulate to comply. Trichloroethylene is a VOC, and 

its use would likely decrease to meet the proposed limit. However, other solvents are 

available that make its use unnecessary. Prohibiting these three TACs will lead to 

approximately 0.12 tons per day of toxic compound emission reductions from this 

category. The health effects associated with exposure to perchloroethylene, methylene 

chloride and trichloroethylene, are summarized in Chapter VIII, Environmental Impacts. 

Issues: 

a. Issue: Non-Chemically Curing Sealants or Caulks serve a wide range of 

applications, including many specialty uses and substrates. The VOC standard 

should allow for the whole range of general use and specialty applications. 

Response: Analysis of 2003 Survey data indicates that 76 percent of the market 

complies with the proposal for the Non-Chemically Curing Sealant or Caulking 
Technical Support Document Chapter VI - 126 

Compound non-aerosol subcategory. Many of these products can be applied to 

a varied range of substrates, including many specialty use applications. Staff 

believes, and some industry stakeholders have agreed, that the proposed VOC 

standard allows for a wide range of general and specialty use product 

applications. 

b. Issue: The lower VOC limit proposed for Non-Chemically Curing Sealant or 

Caulking Compound products will have a negative effect on product 

performance, causing the market to shift to the use of Chemically Curing Sealant 

or Caulking Compound products, which have a higher VOC standard. 

Response: As stated in response to the first issue, staff believes that the 

proposed VOC limit for Non-Chemically Curing Sealant or Caulking Compound 

non-aerosol products will accommodate a wide range of product applications. In 

addition, there are existing products that meet the definition of the Chemically 

Curing Sealant or Caulking Compound non-aerosol subcategory that are low in 

VOC content. These products claim to perform well under extreme weather 

conditions and can be used for many applications. 

c. Issue: Staff is adding pipe thread sealants and gasket makers to the definition of 

Sealant or Caulking Compound. Pipe thread sealants and gasket makers were 

not included in the original proposal to regulate Sealant or Caulking Compounds 

and should not be added to the definition. 

Response: Staff is making a clarification that the Sealant or Caulking Compound 

category definition does include pipe thread sealants and gasket makers as 

these products are designed to fill, seal, waterproof or weatherproof gaps or 

joints between two surfaces. Staff has made a number of product reviews, at the 

request of manufacturers, and determined that such products are subject to the 

Consumer Products Regulation requirements for sealant or caulking compounds. 

A number of chemically curing and non-chemically curing pipe thread sealants 

and gasket makers were reported in the 2003 Survey, with complying products 

existing in both subcategories. 

d. Issue: The proposed lower VOC limits will eliminate the aerosol product form. 

Response: Staff’s proposal sets lower VOC limits for non-aerosol products only. 

The current VOC limit of 4 percent by weight for the Sealant or Caulking 

Compound category is applicable to all product forms and will continue to be 

applicable to aerosol forms. The 2003 Survey indicates that there are products 

utilizing aerosol technologies available on the market, in both the Chemically 

Curing and Non-Chemically Curing Sealant or Caulking Compound non-aerosol 

subcategories that comply with the existing 4 percent by weight VOC limit. 
Technical Support Document Chapter VI - 127 

REFERENCES

1. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

 November, 2004. (ARB, 2004a) 

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

the California Consumer Products Regulation: Midterm Measures II. September, 

10, 1999. (ARB, 1999) 

3. Air Resources Board. Determination of Reasonably Available Control Technology 

and Best Available Retrofit Control Technology for Adhesives and Sealants. 

December, 1998. (ARB, 1998) 

4. House-Painting-Info. Polyurethane Caulk Possibly the Best. March 20, 2008. 

http://www.house-painting-info.com/polyurethane-caulk.html. (April 9, 2008). 

(HPI, 2008) 

5. Macco Adhesives. Notes on Chemically Curing Adhesive and Sealant Systems. 

August 1, 2006. (Macco, 2006) 

6. O’Connor, AE. Silyl-Terminated Polyurethanes for Construction Sealants. 

Kingston, T. ASTM International, Volume 1, Issue 3 – Online Abstract. 

March 10, 2004. 

http://www.astm.org/cgibin/SoftCart.exe/JOURNALS/JAI/PAGES/460.htm?E+my

store. (April 9, 2008). (O’Conner, 2004) 

7. Pontolilo, Brian. Making Sense of Caulks and Sealants. Fine Homebuilding. 

April/May, 2004. http://www.tauton.com/finehomebuilding/PDF/Free/

021162097.pdf. (Pontolilo, 2004) 

15. Spot Removers 

Product Category Description: 

 Spot Removers are used to remove localized spots or stains on articles such as 

carpets, rugs, upholstery, drapes, or clothing. Subsequent laundering is not required to 

achieve stain removal. Spots and stains include visible contamination from spills and 

other mishaps. The distinction between Spot Removers and related cleaning products, 

such as Carpet/Upholstery Cleaner, is that Spot Removers are “on-demand” products 

for local treatment/cleaning of areas with heavier dirt or stains, while the cleaning 

products are for general cleaning of the majority of, or an entire article, after routine 

accumulation of contaminants over time. Generally, Spot Removers use more powerful 

cleaning ingredients than Carpet/Upholstery Cleaners. Some products are intended for 

specific types of soils. Spot Removers do not include products that treat spots and 

stains on clothes or other fabrics that need subsequent laundering (machine or hand 
Technical Support Document Chapter VI - 128 

wash) to remove the stain. Such products are included in the category of Laundry 

Prewash. 

 Spot Removers include products designed to remove tough, localized stains, 

such as grease, oil, oxidized oil (old, dried-out), tar, dry paint spots (latex, oil-based, 

enamels), blood, urine, vomit, feces, most foods, make-up, crayon, lipstick, nail polish, 

floor waxes, rust, or ink. A product may be intended for one type of stain, or for several. 

While the cause and contamination in some spots/stains may be known such that an 

appropriate type of Spot Remover is chosen, others may be of unknown origin. 

“Unknown” spots and stains may be treated by “universal” Spot Removers intended for 

several types of contamination, or by “trial-and-error” with a series of different Spot 

Removers, each for a different type of spot/stain. For treating localized odor 

contamination, Spot Removers may use biologically-derived odor destroying ingredients 

(e.g. enzymes or live bacterial culture). 

 Spot Removers were regulated under “Mid-term Measures 1” of the Consumer 

Products Regulation approved on July 24, 1997, and a description of these products is 

also included in the staff report for that rulemaking (ARB, 1997b). At that time, the 

Board adopted, as staff had recommended, a VOC limit of 25 percent by weight for 

aerosol products, and a VOC limit of 8 percent by weight for non-aerosol products. 

Both VOC limits became effective January 1, 2001. 

The Spot Remover category does not include Dry Cleaning Fluid. Dry Cleaning 

Fluid includes non-aqueous liquid products used exclusively on fabrics labeled "for dry 

clean only" or on "S-coded" fabrics specified by the Joint Industry Fabric Standards 

Committee to be cleaned only with water-free spot cleaning products. 

 Also historically, the category excluded Multi-purpose Solvents, which are 

defined as organic liquid products with no VOC limit. However, the 2006 Consumer 

Products Regulation amendments (ARB, 2006a; ARB, 2007e) to section 94508(a) 

modified requirements. Multi-purpose Solvent products manufactured on or after 

January 1, 2008, with multiple-use claims, are subject to the Spot Remover VOC limit if 

the product label includes a claim for spot or stain removal from fabric surfaces. The 

product would also be subject to the "most-restrictive-limit" provisions of section 

94512(a). 

 Table VI-29 below summarizes the sales and emissions from Spot Remover 

products based on the results of ARB’s 2003 Survey (ARB, 2004a). The data have 

been grown to the 2008 calendar year. Total category sales are 42,308 pounds per 

day. 

 As shown in Table VI-29, Spot Remover products are sold in both the aerosol 

and non-aerosol forms, with estimated VOC emissions of 2,105 pounds per day, or 

about 1.05 tons per day, in California. Although not shown, the sales-weighted average 

VOC content of the aerosol and non-aerosol products are about 22 and 2 percent by 

weight, respectively. 
Technical Support Document Chapter VI - 129 

Table VI-29 

Spot Remover* 

Product Form

Number of 

Products

2008 

Category Sales 

(lbs/day)**

2008 Adjusted 

VOC Emissions 

(lbs/day)**

Aerosol 70 6,910 1,520 

Non-Aerosol 361 35,398 585 

Total 431 42,308 2,105 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a). 

** Survey data adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions).

Product Use and Marketing: 

 Spot Removers are used by household consumers for cleaning localized spots, 

stains, and soiled areas on fabric articles in homes and vehicles. Spot Removers are 

also used by commercial/institutional professionals such as janitors; carpet, furniture, 

drapery, and laundry workers; commercial detailers of automotive interiors; workers in 

health care facilities; and remediation specialists for fabric articles in buildings after 

fire/smoke damage. 

 Spot Removers are applied by aerosol spray, mechanical sprayer, bottle 

dispenser, or special applicator, to the affected area, and left to soak to release/treat the 

spot or stain in the fibers. The area is then blotted with a dry cloth or scrubbing cap to 

lift and remove the contaminants from the substrate. Sometimes repeat application is 

needed to adequately remove the spot or stain. The area may be dampened with water 

from a clean cloth, and blotted with a dry cloth to dilute and remove residual cleaner. 

The area is then allowed to dry (ARB, 1997b). 

 Both Spot Removers and Laundry Pre-wash products claim to treat or remove 

localized spots. However, the products differ in that Laundry Pre-wash products contain 

instructions for treating stains on articles prior to laundering, while Spot Removers do 

not. 

 The Spot Remover category is currently regulated as “aerosol” and “non-aerosol” 

products with different VOC limits. Spot Removers are sold in general merchandise, 

hardware, drug stores, supermarkets, automotive parts stores, janitorial and 

maintenance supply warehouses, and over the Internet. Some products are packaged 

as kits containing products formulated for different types of spots or stains 

(ARB, 1997b). 

Product Formulation: 

 Spot Removers are generally water-based products containing ingredients such 

as glycol ethers, isopropyl alcohol, surfactants, enzymes, and various inorganic 

cleaning compounds. Ingredients vary depending on the types of spots and stains, 
Technical Support Document Chapter VI - 130 

although many products are formulated for general use to address several types of 

stains. A common ingredient is 2-butoxyethanol (also called ethylene glycol monobutyl 

ether) which is used to treat many solvent-based and water-based stains. Other glycol 

ethers are also used, some of which are VOCs, but others are LVP-VOCs and are thus, 

slower drying. 

 Typically, products complying with the current 25 percent VOC limit for aerosols, 

may contain zero to 20 percent VOC cleaners such as VOC glycol ethers, alcohol, or 

other organic compounds such as surfactants, and 5 to 10 percent hydrocarbon 

propellant. Surfactants or enzymes, typically classified as LVP-VOCs, may be part of 

the formulation to clean soils, including oily spots and stains. Enzymes and other 

biologically-derived ingredients, such as non-pathogenic bacterial cultures may be used 

to address odor, grease, and other organic contamination. Some products use oxygen 

compounds (e.g. bleach) to clean stains. With non-VOC propellants such as HFC152a, products may contain up to 25 percent VOC cleaning ingredients under the 

current VOC limit. Some products rely on surfactants, containing minimal or no VOCs, 

for removal of various contaminants including oil and grease. Inorganic ingredients may 

be used as cleaners, or to enhance the cleaning effectiveness of surfactants. 

 The non-aerosol products are generally liquids applied by trigger sprayer, 

hand-pump-pressurized tank sprayer, or bottle dispenser. Low-VOC products are 

typically water-based and may include LVP-VOC cleaners, such as surfactants and 

LVP-VOC glycol ethers, and inorganic ingredients. Some products for 

commercial/institutional use are sold in dilutable (i.e. concentrated) liquid form. 

 Specialized products also exist in this category. For example, products 

containing mainly acid or bleach (inorganic and thus zero-VOC) are used to remove rust 

and certain water-based stains. 

Proposed VOC Limit and Compliance: 

 The proposed VOC limit for Spot Remover is 15 percent by weight for aerosols 

and 3 percent by weight for non-aerosols, effective December 31, 2010. As shown in 

Table VI-30, using emissions adjusted to 2010, the proposed limits for the category will 

result in an estimated emission reduction of 573 pounds per day, or about 0.29 tons per 

day statewide. 

 Table VI-30 also shows that about 4 percent of the aerosol market currently 

complies with the proposed 15 percent VOC limit, and 94 percent of the non-aerosol 

market complies with the 3 percent VOC limit. 
Technical Support Document Chapter VI - 131 

Table VI-30 

Spot Remover Proposal*

Product Form

Proposed 

VOC Limit 

(wt. %)

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emission 

Reductions 

(lbs/day)** 

2010 

Emission 

Reductions 

(lbs/day)+

Aerosol 15 18 4 468 479 

Non-Aerosol 3 231 94 91 94 

Total ----- 249 ----- 559 573 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a). 

** Emission reductions adjusted for complete market coverage and grown, by population, to 2008 

(see Chapter IV, Emissions). 

+ Emission reductions adjusted for complete market coverage and grown, by population, to 2010 

(see Chapter IV, Emissions). 

 The proposed 15 percent VOC limit for aerosol products is intended to allow both 

sufficient VOC solvent for removing grease or oil-type spots and stains, and sufficient 

hydrocarbon propellant for adequate spray performance. Products may be formulated 

to contain LVP-VOCs and non-VOC ingredients such as surfactants, enzymes, live 

bacterial cultures, inorganic compounds, or exempt compounds. 

 Alternative formulations with non-VOC propellant would enable up to 15 percent 

VOC solvent ingredients, with the addition of non-VOC ingredients as discussed above. 

Non-VOC propellants available include compressed carbon dioxide. 

 A reformulation option is limited use of acetone (a VOC exempt compound). 

Because it is an aggressive solvent that may damage common materials, acetone may 

have limited applications for certain fabrics with nearby surfaces vulnerable to 

over-spray. Acetone is not suitable for use on acetate, triacetate, and modacrylic 

fabrics, and must be used away from plastic or wood finishes. Acetone, as well as 

certain other organic and hydrocarbon solvents, may have limited use with carpets and 

rugs with vulnerable backing material. Because of its fast drying characteristics, 

acetone in a formulation may be used to supplement and partially offset the slower 

drying characteristics of LVP-VOC ingredients. 

 Regarding non-aerosol products, the VOC proposal would allow up to 3 percent 

VOC cleaning solvent. The balance would be primarily water with small amounts of 

LVP-VOC solvents, acetone, surfactants, enzymes, live bacterial cultures, inorganic 

compounds, or other exempt compounds. 

 The few products with perchloroethylene (an exempt chlorinated compound and 

thus non-VOC) are aerosols and generally low-VOC. However, the combined sales of 

these products were minimal and are not portrayed in the complying market share. The 

15 percent VOC proposal is minimally affected by the presence or absence of the 

perchloroethylene products in the data. The 2003 Survey data show very limited use of 
Technical Support Document Chapter VI - 132 

perchloroethylene and trichloroethylene (a VOC chlorinated compound) in this category. 

While ARB staff believes these toxic air contaminants are not likely to be used as 

cleaning solvents in the future reformulated products, ARB staff is proposing that 

perchloroethylene, trichloroethylene, and methylene chloride be prohibited in the Spot 

Remover category. This prohibition is proposed to ensure that manufacturers do not 

choose to reformulate with toxic chlorinated solvents in response to the lower VOC 

limits. Staff has determined that currently available formulation technologies that do not 

contain perchloroethylene, trichloroethylene, or methylene chloride are readily available 

and thus they are not needed to comply with the proposed standard. See Chapter VIII 

for a discussion of the health effects of perchloroethylene, trichloroethylene, and 

methylene chloride. 

 To update and strengthen regulatory requirements, the Multi-purpose Solvent 

exclusion in the definition is proposed to be eliminated. This revision would make the 

requirements for Spot Remover consistent with the adopted 2006 update for Multipurpose Solvent. Also, when a product is subject to more than one VOC limit, the most 

restrictive limit would apply, in accordance with section 94512(a). 

 A new exclusion for aerosol gum remover products is proposed for the category 

definition. A literal interpretation of the current Spot Remover definition may include 

aerosol gum removers, since gum contamination on fabric may be considered "spots." 

Since the formulation and method of operation of aerosol gum removers are very 

different from typical Spot Removers, staff believes it is not appropriate to include 

aerosol gum removers in this category. Aerosol gum remover products, will be 

evaluated for regulation in the future. 

Issues:

a. Issue: VOC solvents are needed to remove oil-based stains such as lipstick, nail 

polish, ink, tar, oxidized oils (old, dried-out), dry paint spots (latex, oil-based, 

enamels), floor waxes, and crayon. LVP-VOC solvents do not work well because 

they do not evaporate quickly and are very sticky. The resulting sticky residues 

attract more soil. The cleaning of fabrics is different than the cleaning of hard 

surfaces, which can be easily wiped off for faster drying. 

Response: When LVP-VOC solvent cleaners are used, the extent of the slower 

drying time will depend on the amount used, how thoroughly residual cleaners 

are diluted and removed, and how crucial the longer drying time is. Products 

already exist with LVP-VOC solvent cleaners, as indicated by the 2003 Survey, 

that comply with the proposed VOC limits. For products that will need 

reformulation, greater use of a wet cloth for diluting residual cleaners, and more 

thorough blotting with dry absorbent cloth, may be appropriate. Increased 

caution and customer education by product marketers, to avoid product-over-use 

and encourage appropriate drying procedures and proper article return-toservice, should address the concerns with LVP-VOCs.
Technical Support Document Chapter VI - 133 

b. Issue: This category includes a broad range of products for a variety of fabrics 

and soils. Reported products include many based on non-VOC ingredients, such 

as bleach, hydrogen peroxide, acid, or surfactant, which are appropriate for some 

types of soils. Hydrogen peroxide, hypochlorite, and certain enzymes can not be 

used on all types of fabrics due to possible damage to fabrics. There is a wide 

range of VOC levels, which reflect the variety of intended uses. In some cases, 

higher VOC levels are needed to remove difficult stains and soils. 

Response: We have considered the functions of low-VOC products and 

inorganic ingredients for particular types of spots and stains, as well as the 

advantages and limitations. We are also aware that many complying products 

make universal spot removing claims, some not needing VOC solvents. High 

VOC products may create emissions without a cleaning benefit when treating 

spots and stains that do not need VOC solvents. Our proposal addresses both 

those products for specific spot removal, and products for general spot removal. 

Regarding damage to fabrics, the product marketer should determine the type of 

product for the type of spots and stains to be addressed for different fabrics and 

articles, and to provide appropriate label warnings. Label instructions now 

commonly suggest that the customer test the Spot Remover on an inconspicuous 

location on the fabric before fully using it. 

c. Issue: Products containing perchloroethylene (an exempt compound) in the 

2003 Survey data provide a false impression of the extent of low-VOC products. 

These products should be removed from the data, since use of 

perchloroethylene, a toxic air contaminant, should not be considered a realistic 

reformulation option to lower VOC content in this category. 

Response: We agree that perchloroethylene products should not be relied on 

as a basis to lower VOC limits. We also believe that these products should not 

be marketed in the future because of air toxics concerns. However, the amount 

of product sales in 2003 with this compound was low and minimally affected the 

complying market share or the basis of our proposal, as discussed above. We 

have also reviewed the survey data with and without the perchloroethylenecontaining products, and have presented the 2003 Survey results with the 

products included since that was the historical reality at the time. We believe 

there is no misrepresentation of the survey results as shown. 

d. Issue: Products with label claims for general carpet cleaning, in addition to 

localized cleaning, should be move from the Spot Remover category to the 

Carpet/Upholstery Cleaner category. 

Response: To a certain extent, we agree that products should be considered in 

one product category or another. If a product is labeled clearly as 

Carpet/Upholstery Cleaner with only incidental use as Spot Remover, we would 

agree. However, a product label may have several equally important recommend 

uses, and thus fall under more than one category. For regulatory development 

purposes, a product as labeled may be appropriately considered in more than 
Technical Support Document Chapter VI - 134 

one categories for review, depending on the wording of the various category 

definitions and the product label, although the regulatory emission reduction 

should be counted for only one category. We also consider the category 

identified by the marketer, since the marketer is most familiar with the product 

and has the first opportunity to categorize the product when submitting the 

survey. Please note that data review is separate from any enforcement 

evaluation for individual products. 

e. Issue: ARB should regulate non-aerosol Spot Removers used by dry cleaning 

establishments. Water-based and soy-based alternative Spot Removers are 

available alternatives to the currently used and more toxic perchloroethylene and 

trichloroethylene-based Spot Removers. Alternative Spot Removers perform well 

and are less costly. 

Response: While currently available data are encouraging for spot removal for 

water-tolerant or water-washable articles, data are currently lacking on suitable 

low-VOC, non-chlorinated, Spot Remover products for dry-clean-only fabrics. 

ARB staff intends to reevaluate the "dry-clean-only" exclusion in the Spot 

Remover definition, when more data become available regarding the suitability of 

low-VOC, non-chlorinated products for use on dry-clean-only fabrics. However, 

with products for other types of fabric (i.e. water-tolerant or water-washable), the 

exclusion does not apply, and hence the proposed VOC limits would apply to 

Spot Remover products labeled for general spot removal (i.e. suitable for watertolerant or water-washable fabrics) that may be used in dry cleaning 

establishments. 

REFERENCES 

1. Air Resources Board. Final Statement of Reasons for Rulemaking, Including 

Summary of Comments and Agency Responses -- Public Hearing to Consider 

Adoption of Proposed Amendments to the California Consumer Products 

Regulation and the Aerosol Coatings Regulation - Scheduled for Consideration 

November 17, 2006 - Agenda Item No. 06-10-8. Submitted to Office of 

Administrative Law on September 26, 2007. (ARB, 2007e) 

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

the California Consumer Products Regulation and the Aerosol Coatings 

Regulation. September 29, 2006. (ARB, 2006a) 

3. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

 November, 2004. (ARB, 2004a) 

4. Air Resources Board. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation: Midterm Measures I. 

June 6, 1997. (ARB, 1997b) 
Technical Support Document Chapter VI - 135 

5. Institute for Research and Technical Assistance. Spotting Chemicals: 

Alternatives to Perchloroethylene and Trichloroethylene in the Textile Cleaning 

Industry. Prepared by Katy Wolf and Mike Morris for Cal/EPA's Department of 

Toxic Substances Control and U.S. Environmental Protection Agency Region IX. 

January 2007. (IRTA, 2007) 

6. Institute for Research and Technical Assistance. Evaluation of New and 

Emerging Technologies for Textile Cleaning. Prepared by Michael Morris and Dr. 

Katy Wolf for Air Resources Board and Cal/EPA (Agreement Number 02-408), 

and U.S. Environmental Protection Agency. August, 2005. (IRTA, 2005) 

16. Tire or Wheel Cleaner

Product Category Description: 

Tire or Wheel Cleaner means a product designed or labeled exclusively to clean 

either tires, wheels, or both. Tire or Wheel Cleaner includes, but is not limited to, 

products for use in commercial, fleet, hand, and “drive-through” car washes, commercial 

truck or large vehicle washing stations, vehicle dealers and repair shops as well as 

products intended for household consumer use. Tire or Wheel Cleaners include aerosol 

products as well as non-aerosol products, which can be found in both dilutable and 

ready-to-use forms. Tire or Wheel Cleaners do not include products identified as 

Rubber/Vinyl Protectant and Motor Vehicle Wash. 

Tire or Wheel Cleaner is a previously unregulated category. Table VI-31 below 

summarizes the sales and emissions from Tire or Wheel Cleaners based on the results 

of ARB’s 2003 Survey (ARB, 2004a). The data have been grown to the 2008 calendar 

year. Total category sales are about 9,829 pounds per day. 

Table VI-31 

Tire or Wheel Cleaner* 

Product Form

Number of 

Products

2008 

Category Sales 

(lbs/day)**

2008 Adjusted 

VOC Emissions 

(lbs/day)**

Aerosol 8 189 17 

Non-aerosol 102 9,640 278 

Total 110 9,829 295 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a). 

** Survey data adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions).

 

Estimated VOC emissions are 295 pounds per day, or about 0.15 tons per day. 

As shown in Table VI-31, non-aerosol Tire or Wheel Cleaner products dominate the 

marketplace. Although not shown in the table, aerosol Tire or Wheel Cleaners have a 
Technical Support Document Chapter VI - 136 

sales-weighted average of about 8 percent by weight VOC, while the non-aerosol 

products have a sales-weighted average of 2 percent by weight VOC. 

Product Use and Marketing: 

 Tire or Wheel Cleaners are used by both commercial businesses and “do-ityourself” consumers. For the “do-it-yourself” consumers, tire cleaners, wheel cleaners, 

and combination tire and wheel cleaners are available in, but not limited to, retail outlets 

such as supermarkets, diversified pharmacies, home improvement stores, auto supply 

stores, super stores, and specialty stores. Auto dealers, catalog sales, and the Internet 

are additional marketing locations. For commercial businesses, products are available 

from manufacturers and/or distributors, and warehouses as well as retail outlets. 

 Tire or Wheel Cleaners are normally designed to be sprayed onto the part and 

then washed or wiped off. The majority of the products in this category are non-aerosol 

products that are designed to be applied either by pump spray or diluted with water 

before use. Tire or Wheel Cleaner products claim to remove dirt, debris, and other soils 

from the surfaces of tires, wheels, or both. Most wheel cleaners claim to be available 

for use on all wheel surfaces, including chrome and aluminum. Tire cleaners claim to 

be usable on either regular tires or specifically on whitewall tires. 

Product Formulation: 

 Tire or Wheel Cleaners are water-based products containing glycol ethers, 

alcohols, VOC and LVP-VOC hydrocarbon solvents, and inorganic compounds. The 

glycol ethers, VOC solvents, and alcohols make up the majority of the product’s VOC 

content and act as the active ingredients. The inorganics and LVP-VOC solvents are 

normally surfactants to aid in cleaning. The aerosol products normally use a small 

amount of hydrocarbon propellant. 

Proposed VOC limit and Compliance: 

 The proposed VOC limits for aerosol and non-aerosol Tire or Wheel Cleaner are 

8 and 2 percent VOC by weight, respectively, effective December 31, 2010. As shown 

in Table VI-32 using adjusted emissions, the proposed limits will result in an estimated 

reduction of 130 pounds per day, or about 0.06 tons per day. 

Table Vl-32 also shows that 69 percent of the non-aerosol market currently 

complies with the proposed VOC limit. The percent of the market that currently 

complies with the proposed aerosol limit of 8 percent VOC is small and therefore treated 

as confidential. 
Technical Support Document Chapter VI - 137 

Table Vl-32 

Tire or Wheel Cleaner Proposal* 

Product Form

Proposed 

VOC Limit 

(wt. %)

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emission 

Reductions 

(lbs/day)** 

2010 

Emission 

Reductions 

(lbs/day)+

Aerosol 8 *** *** 2 2 

Non-aerosol 2 63 69 126 128 

Total ___ ___ ___ 128 130 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a).

** Emission reductions adjusted for complete market coverage and grown, by population, to 2008 

(see Chapter IV, Emissions).

+ Emission reductions adjusted for complete market coverage and grown, by population, to 2010 

(see Chapter IV, Emissions).

 

Most of the non-complying products are already formulated close to the proposed 

limits, so the proposed effective date is feasible. The few manufacturers that would 

have to reformulate should be able to meet the proposed limits by increasing the 

product’s water and/or LVP-VOC content. 

REFERENCES 

1. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

November, 2004. (ARB, 2004a) 

17. Windshield Water Repellent

Product Category Description: 

 Windshield Water Repellents are products designed or labeled exclusively to 

repel water from motor vehicle windshields and other exterior glass surfaces. These 

products claim to improve driving visibility during inclement weather by repelling rain, 

sleet and snow. Windshield Water Repellents do not include Automotive Windshield 

Washer Fluid. Automotive Windshield Washer Fluids are designed, or labeled, to clean 

glass surfaces, while Windshield Water Repellents are applied to surfaces that have 

already been cleaned. 

 Windshield Water Repellent is a previously unregulated category. Table VI-33 

below summarizes the sales and emissions from Windshield Water Repellent based on 

the results of ARB’s 2003 Survey (ARB, 2004a). The emissions have been grown to 

the 2008 calendar year. Total category sales are about 538 pounds per day. 
Technical Support Document Chapter VI - 138 

Table VI-33 

Windshield Water Repellent* 

Product Form

Number of 

Products

2008 

Category Sales 

(lbs/day)**

2008 Adjusted 

VOC Emissions 

(lbs/day)**

All Forms 30 538 462 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a).

** Survey data adjusted for complete market coverage and grown, by population, to 2008 (see 

Chapter IV, Emissions).

 As shown in Table VI-33, Windshield Water Repellent products have estimated 

VOC emissions of 462 pounds per day, or about 0.23 tons per day, in California. 

Although not shown, Windshield Water Repellent has a sales-weighted average VOC 

content of about 86 percent. 

Product Use and Marketing: 

 Windshield Water Repellents are used by both commercial businesses and “doit-yourself” consumers. For the “do-it-yourself” consumers, Windshield Water 

Repellents are available in, but not limited to, retail outlets such as supermarkets, 

diversified pharmacies, home improvement stores, auto supply stores, super stores, 

and specialty stores. Auto dealers, catalog sales, and the Internet are additional 

marketing locations. Products for commercial businesses are available from 

manufacturers and/or distributors, and warehouses, as well as retail outlets. Windshield 

Water Repellents are sometimes applied to glass surfaces by the original equipment 

manufacturer. 

 Windshield Water Repellent products are sprayed, or rubbed, onto clean, exterior 

windshields and other glass surfaces to provide a water repellent coating. This coating 

repels rain by producing a high water contact angle such that bead droplets form and 

roll down the surface, instead of sticking to the glass, leaving the windshield clear 

(CSPA, 2006). This is especially useful during the more hazardous weather conditions 

that contribute to lowered visibility. 

Product Formulation: 

 Windshield Water Repellents have essential performance needs. They must 

provide a static, high, contact angle. Water should bead and roll down the windshield, 

rather than leave a droplet trail, and it must function with the current windshield wiper. 

Use of the product must not result in abrasion, streaking, or haze on the glass, due to 

the product’s use, as these instances would reduce visibility, thereby becoming a 

potential consumer safety issue. 

 To provide this function, Windshield Water Repellents are typically formulated 

with alcohols and inorganics. The alcohols provide solvency for the inorganic coating, 

normally a surfactant, so that it can be readily applied onto the surface of the windshield 
Technical Support Document Chapter VI - 139 

or other automotive glass surfaces. Alcohol-based products with a silicone catalyst 

dominate the market. Some products were also found to contain LVP-VOC 

compounds, as well as VOC propellants. 

 Available technologies include silicone with an acid catalyst, organo-silanes, 

silicone functionalized surfactants, carnauba wax, silicone emulsion, diamond-like 

carbon coatings, and hydrophobic treated nano-particulates (CSPA, 2006). 

Proposed VOC Limit and Compliance: 

 The proposed VOC limit for Windshield Water Repellent is 75 percent, by weight, 

effective December 31, 2010. As shown in Table VI-34, using adjusted emissions, the 

proposed limit will result in an estimated emission reduction of 84 pounds per day, or 

about 0.04 tons per day. 

 Table VI-34 also shows that the percent of the market that currently complies 

with the proposed 75 percent VOC limit is small and therefore treated as confidential. 

Table VI-34 

Windshield Water Repellent Proposal*

Product Form

Proposed 

VOC Limit 

(wt. %)

Complying 

Products

Complying 

Market 

Share (%)

2008 

Emission 

Reductions 

(lbs/day)** 

2010 

Emission 

Reductions 

(lbs/day)+

All Forms 75 *** *** 83 84 

* Based on 2003 Consumer and Commercial Products Survey (ARB, 2004a).

** Emission reductions adjusted for complete market coverage and grown, by population, to 2008 

(see Chapter IV, Emissions).

+ Emission reductions adjusted for complete market coverage and grown, by population, to 2010 

(see Chapter IV, Emissions).

 

 Water-based technology, for Windshield Water Repellent, is being researched by 

manufacturers. However, at present time, further development is necessary. We 

believe that technology is advancing that would allow lower VOC products in the future. 

The proposed 75 percent VOC limit is set as low as current technology allows. Staff 

believes manufacturers will be able to use current LVP-VOC technology to formulate 

effective products while developing the technology to implement more LVP-VOC solvent 

use as well as water-based technology. 

Issues:

a. Issue: The effective date for the limit should be extended until 2012 to allow 

adequate time for reformulation. 

Response: Staff believes that the current effective date of 2010 is sufficient time 

to allow for reformulation to meet the proposed 75 percent VOC limit and make 
Technical Support Document Chapter VI - 140 

complying products available in the marketplace. We also note that in a 2006 

presentation industry indicated that a 75 percent VOC limit was feasible. 

REFERENCES 

1. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

 November, 2004. (ARB, 2004a) 

2. Consumer Specialty Products Association. CSPA Automotive and Solvent 

Products Technical Seminar for ARB Staff. July 13, 2006. (CSPA, 2006) 

B. CATEGORIES FOR WHICH A GREENHOUSE GAS LIMIT IS PROPOSED 

1. Pressurized Gas Duster

Product Category Description:

Pressurized Gas Duster is a product designed to remove foreign particles such 

as dust, dirt, lint, and other particles from sensitive equipment and materials, solely by 

the means of mass air or gas flow. Pressurized Gas Dusters are distinguished from 

Electronic Cleaners which remove foreign particles primarily by means of a solvent. 

The Board first defined Pressurized Gas Duster in the 2004 rulemaking (ARB, 

2004b). However, at that time, no VOC standard for Pressurized Gas Duster was 

established. 

In this rulemaking, we are proposing to limit the global warming potential (GWP) 

of compounds used in Pressurized Gas Dusters. To implement this proposal, we are 

proposing to add definitions for “Global Warming Potential” and “Global Warming 

Potential Value.” These definitions are necessary to implement our proposal to reduce 

the potency of greenhouse gas emissions from Pressurized Gas Dusters. We are using 

the GWP definition of the Intergovernmental Panel on Climate Change (IPCC). GWP 

provides a measure of a compound’s impact on global warming compared to CO2. The 

GWP value definition specifies that the 100-year GWP values in the Second 

Assessment Report (SAR) of IPCC would be used to determine compliance. To 

enforce our proposal to reduce greenhouse gas emissions from Pressurized Gas 

Duster, the definition further specifies that, if the SAR does not contain a GWP value for 

a specific chemical or compound, then the IPCC, Fourth Assessment Report (FAR) 

GWP value for that chemical or compound can be used. If there is no GWP value listed 

for a specific chemical or compound in the SAR or the FAR, then the GWP value is 

assumed to be equal to the GWP applicable standard.

As defined by the Intergovernmental Panel on Climate Change 1995: Second 

Assessment Report (IPCC, 1996), the GWP of a greenhouse gas (GHG) is defined as 

the radiative forcing impact of one mass-based unit of a given greenhouse gas relative 
Technical Support Document Chapter VI - 141 

to an equivalent unit of carbon dioxide over a given period of time. The standard units 

of measurement used to express the emissions of a GHG are million metric tons of 

carbon dioxide equivalent (MMT CO2e) per year. 

The global warming potential (GWP) of products in this category is high due to the 

use of hydrofluorocarbon-134a (HFC-134a) and hydrofluorocarbon-152a (HFC-152a). 

HFC-152a has a GWP of 140, which is one hundred and forty times greater than the 

GWP of carbon dioxide (CO2). HFC-134a has a GWP of 1300, which is approximately 

ten times greater than the GWP of HFC-152a and 1300 times greater than CO2 (IPCC, 

1996; IPCC, 2007). 

We are also proposing to modify the definition for Pressurized Gas Duster to 

exclude electronic cleaners, electrical cleaners, or energized electrical cleaners. 

However, we are proposing to add an exemption to the definition for the niche uses 

where non-flammable dusters are needed. HFC-134a is a non-flammable propellant, 

whereas HFC-152a is moderately flammable. The proposed exemption is for nonflammable products labeled exclusively to remove dust from equipment where dust 

removal is accomplished when: electric current exists; residual electrical potential from 

a component such as a capacitor exists; or an open flame exists. In addition, the 

product’s “Principal Display Panel” must clearly contain the statement: “Energized 

Equipment use only.” Additionally, to ensure that there are no increases in VOC or air 

toxics emissions, as a result of the proposed GWP limit, staff is proposing a 1 percent 

by weight VOC standard and a prohibition on the use of perchloroethylene and 

methylene chloride as mitigation measures as required by the California Environmental 

Quality Act (CEQA). 

The GHG emission reductions from the Pressurized Gas Dusters were estimated 

using reported information from the 2003 Consumer Products Survey and the 2007 

Pressurized Gas Duster Survey Update gathered during February 2008. During the 

public process of developing the proposed GWP limit, staff held numerous meetings 

and teleconferences to solicit information and comments from industry associations and 

industry representatives. At that time, industry representatives advised ARB staff that 

changes in the gas duster market had occurred since 2003. In response, staff 

conducted the 2007 Pressurized Gas Duster Survey Update to collect updated 

information. 

The emissions and reduction estimates for 2010 and 2020 were grown from 2007 

sales data and the state Department of Finance’s population estimates. Annual 

population growth factors were calculated using the 2007 state population figures and 

the California Environmental Protection Agency’s (Cal/EPA) Statewide Human 

Population Table found in the Population and Vehicle Trends Report (ARB, 2008d). It 

was assumed that without the proposed GWP limit for Pressurized Gas Dusters, the 

annual sales would grow proportionate to population growth. Staff used GWP values 

from the IPCC Climate Change 1995; The Science of Climate Change (IPCC, 1996) for 

calculating the CO2 equivalent emissions and CO2 equivalent reductions for this 

category of products. 
Technical Support Document Chapter VI - 142 

 Table VI-35 below summarizes the 2003 and 2007 sales and GHG emissions 

from Pressurized Gas Dusters based on the results of ARB’s 2003 Survey 

(ARB, 2004a) and the 2007 Pressurized Gas Duster Survey Update (ARB, 2008c). 

 As shown in Table VI-35, 39 duster products were reported for 2003 with adjusted 

sales of 3,657 pounds per day for 2008. Although not shown on the table, Pressurized 

Gas Dusters had a sales-weighted average GHG content of over 99 percent by weight, 

with estimated GHG emissions of 2,242,171 CO2e pounds per day, or about 

0.37 MMT CO2e per year in California. 

Table VI-35 

Pressurized Gas Duster 

Survey 

Data

Product 

Form 

Number of 

Products

2008 

Category Sales 

(lbs/day)

2008 Adjusted 

GHG Emissions 

(CO2e lbs/day)+ 

2003* Aerosol 39 3,657 2,242,171 

2007** Aerosol 90 7,292 2,179,855 

 * Based on 2003 Consumer and Commercial Products Survey. (ARB, 2004a) 

 ** Based on 2007 Pressurized Gas Duster Survey Update. (ARB, 2008c) 

 + Survey emissions adjusted for complete market coverage (see Chapter IV, Emissions).

 Additionally, as shown in Table VI-35, 90 duster products were reported for 2007 

with adjusted sales of 7,292 pounds per day for 2008. Although not shown in the table, 

the sales-weighted average GHG content is over 99 percent by weight, and the 

estimated adjusted GHG emissions are 2,179,855 CO2e pounds per day, or about 0.36 

MMT CO2e per year. 

 Prior to 2003, industry leaders voluntarily shifted away from using HFC-134a as 

the propellant in gas dusters to using HFC-152a (CSPA, 2008). Changes in the market 

between 2003 and 2007 were captured in the 2007 Pressurized Gas Duster Survey 

Update (ARB, 2008c). In 2003, HFC-134a gas dusters made up approximately 41 

percent of the market. The updated sales information shows that HFC-134a gas 

dusters were approximately 14 percent of the market in 2007, while HFC-152a gas 

dusters made up 85 percent of the market. This is why the 2008 adjusted GHG 

emissions have not increased proportionate to the category sales, which have nearly 

doubled. The potency of GHG emissions from this category have been decreasing with 

the increased use of HFC-152a. 

Product Use and Marketing: 

Pressurized Gas Dusters are aerosol sprays that produce a burst of pressurized 

gas that is used to remove dust, dirt, lint and other particles from a surface. Pressurized 

Gas Dusters differ from products such as “Electronic Cleaners” as they do not use 

liquids or solvents to remove dirt or grease. 
Technical Support Document Chapter VI - 143 

These products are used in applications where no-touch, moisture-free, precision 

cleaning is needed, or in cleaning applications of hard to reach, hidden spots, in 

equipment and delicate instruments and their housings. 

 Pressurized Gas Dusters are used by “do-it-yourself” consumers, technicians, 

and professional engineers. These products are used in applications such as cleaning 

computers and other internal workings of equipment and delicate instruments, in 

addition to the surface of delicate materials such as photographic lenses, photographs, 

film, and negatives that require no-touch, moisture-free cleaning. They are often 

marketed as no residue, moisture-free, ultra pure or filtered to 0.2 micrometers, and 

plastics safe. 

These products are labeled for cleaning delicate equipment such as: electronic, 

photographic and office equipment; laboratory equipment and medical devices; audio 

and video equipment; computer keyboards and printers, the inside of computer 

housings, copiers and TVs; disc drives, and tape heads of cassette players. These 

products are also used to clean delicate materials such as: photographs, photographic 

film, negatives, and slides; audio and video cartridges and cassettes, and other types of 

surfaces that cannot be cleaned with solvents. These products are sometimes labeled 

“For Industrial and Institutional Use Only.” 

 Pressurized Gas Dusters are sold in computer and electronic stores, mass 

market chain-stores, warehouse club stores, office supply stores, hardware stores, 

scientific or laboratory supply catalogs, and on the Internet. 

Product Formulation: 

 Pressurized Gas Dusters are composed of 99 – 100 percent propellant. The 

propellant is typically a hydrofluorocarbon (HFC): HFC-134a or HFC-152a. A few 

products are composed of a blend of hydrocarbon propellants or a blend of hydrocarbon 

propellants, HFC-134a, and dimethyl ether (DME). Some formulations may contain a 

bittering agent (to prevent product misuse), or other additives at trace concentrations. 

The GWP for products in this category is high due to the use of HFC-134a and 

HFC-152a. As mentioned previously, HFC-152a has a GWP of 140, which is one 

hundred and forty times greater than the GWP of carbon dioxide (CO2). HFC-134a has 

a GWP of 1300, which is approximately ten times greater than the GWP of HFC-152a 

and 1300 times greater than CO2 (IPCC, 1996; IPCC, 2007). 

Proposed GWP Limit and Compliance: 

 We are proposing a GWP limit of 150 for any chemical compound used in 

Pressurized Gas Duster products, effective December, 31, 2010. The GWP limit does 

not apply to any chemicals present as contaminants, which, in aggregate, are 
Technical Support Document Chapter VI - 144 

0.1 percent by weight or less. The proposed GWP limit for Pressurized Gas Dusters is 

designed to be equivalent to reducing 0.20 MMT CO2e per year, effective December 31, 

2010, with HFC-134a emissions reductions of approximately 0.23 MMT CO2e per year 

by 2020. The reductions in 2020 are important because AB 32 requires a reduction of 

GHG emissions equal to the 1990 baseline level in California by the year 2020.

We expect that compliance with the proposed limit will be achieved by 

substituting HFC-152a with a GWP of 140 for the HFC-134a propellant with a GWP of 

1300. Pressurized Gas Dusters formulated with HFC-152a already exist on the market 

today. 

As shown in Table VI-36a using adjusted 2007 emissions, we expect an 

estimated emission reduction of 1,198,574 CO2e pounds per day, or about 

0.20 MMT CO2e tons per year, by 2010. The GWP limit was set at 150 rather than 140 

because it is anticipated that GWP values may change as the “state-of-the-science” 

evolves. The GWP of HFC-152a (140) was used to estimate emission reductions. 

Table VI-36a below shows the emission reductions from the GWP limit of 150 for 

this category, and that about 86 percent of the market currently complies with the limit. 

Table VI-36a 

Pressurized Gas Duster GHG Proposal

Survey 

Data

Proposed 

GWP Limit

Complying 

Products

Complying 

Market Share 

(%)

2010 

Emission 

Reductions 

(CO2e lbs/day)+

2020 

Emission 

Reductions 

(CO2e lbs/day)+

2003* 150 7/39 59 1,776,263 2,007,387 

2007** 150 18/90 86 1,198,574 1,348,396 

* Based on 2003 Consumer and Commercial Products Survey. (ARB, 2004a) 

** Based on 2007 Pressurized Gas Duster Survey Update. (ARB, 2008c) 

+ Survey emissions adjusted for complete market coverage (see Chapter IV, Emissions). 

 Note: Emission reductions have been adjusted from 2003 to 2008 using a population growth factor. 

 

 Reformulation options that could be used by manufacturers to meet the proposed 

limit include the use of 100 percent HFC-152a. We are aware of some compressed 

CO2 duster products available on the Internet. Staff initially considered a technology 

forcing, second tier lower limit of 10 for Pressurized Gas Dusters, effective 

December 31, 2015, based on CO2 technology and new lower GWP refrigerant 

technology. However, after further investigation and discussions with manufacturers, 

staff believes that CO2 (compressed gas) dusters are a different product than 

Pressurized Gas Dusters that use liquefied propellant. Dusters using CO2, as they exist 

today, are not a commercially competitive product (DuPont & Falcon, 2004). 

 We are also aware of new lower GWP refrigerants in development. Indications 

are that these new refrigerants may have very low GWPs. The newly emerging 
Technical Support Document Chapter VI - 145 

refrigerants are in the process of under going toxicity and safety testing, and the results 

are not yet available. The VOC status of these new refrigerants and their applicability 

for use as propellants in consumer products, particularly Pressurized Gas Dusters, is 

unknown at this time. Staff intends to work with Pressurized Gas Duster manufacturers, 

and other stakeholders to monitor new technologies and conduct a technical 

assessment of low-GWP propellants that might be appropriate for Pressurized Gas 

Dusters in the future. 

Proposed VOC Limit and Compliance: 

 We are also proposing a 1 percent by weight VOC limit, effective 

December 31, 2010. The limit is designed to prevent the use of hydrocarbon 

propellants, and other VOCs, as products are reformulated to meet the 150 GWP limit. 

Hydrocarbon propellants (butane, propane, isobutane) may have lower GWPs, but 

contribute to the formation of ground-level ozone. As proposed, the VOC limit would 

also apply to any added fragrance. We believe the limit is feasible even if a small 

amount of fragrance is added. Therefore, we are proposing, in section 94510(c), that 

Pressurized Gas Dusters do not qualify for the two percent by weight fragrance 

exemption. The 1 percent limit is designed as a CEQA mitigation measure to prevent 

VOC emission increases. From the standpoint of cleaning shots and total cleaning 

force available per container and potential environmental impact, HFC-152a is more 

efficient than HFC-134a or CO2 (DuPont & Falcon, 2004). As shown in Table VI-36b, 

using 2008 VOC emissions, the proposed limit will result in an estimated emission 

reduction of 1.0 pound per day, or about 0.0005 tons per day. 

 Table VI-36b also shows that more than 99 percent of the market currently 

complies with the proposed 1 percent VOC limit. 

Table VI-36b 

Pressurized Gas Duster VOC Proposal

Survey Data

Proposed 

VOC Limit 

(wt. %)

Complying 

Products

Complying 

Market Share 

(%)

2010 

Emission 

Reductions 

(lbs/day)**

2007** 1.0 89/90 >99 1.0 

** Based on 2007 Pressurized Gas Duster Survey Update. (ARB, 2008c)

+ Survey emissions adjusted for complete market coverage (see Chapter IV, Emissions).

 We expect products to be able to comply with both the VOC and GWP limits 

using HFC-152a. HFC-152a is negligibly reactive with respect to ozone formation and 

has been excluded from the definition of VOC. While ARB staff believes toxic air 

contaminants are not likely to be used in future reformulated products, ARB staff is 

proposing that perchloroethylene and methylene chloride be prohibited in the 

Pressurized Gas Duster category. This prohibition is proposed to ensure that 

manufacturers do not choose to reformulate with toxic chlorinated solvents in response 

to the new VOC and GWP limits. The prohibition does not apply to any chemicals 
Technical Support Document Chapter VI - 146 

present as contaminants, which, in aggregate, are 0.1 percent by weight or less. Staff 

has determined that currently available formulation technologies that do not contain 

perchloroethylene or methylene chloride are readily available and thus they are not 

needed to comply with the proposed standard. See Chapter VIII for a discussion of the 

health effects of perchloroethylene and methylene chloride. 

Issues:

a. Issue: Industry recommends a narrow exclusion in the definition, for products 

that are completely nonflammable. 

Response: The proposed modification to the definition of Pressurized Gas 

Duster includes a narrow exemption for products that are labeled exclusively to 

remove dust from equipment where dust removal is accomplished when: electric 

current exists; residual electrical potential from a component such as a capacitor 

exists; or an open flame exists. In addition, the “Principal Display Panel” must 

clearly contain the statement: “Energized Equipment use only.” [Title 17, CCR, 

Section 94508(a)(118)] 

b. Issue: Industry recommends that the GWP values contained in the IPCC 4th 

Assessment Report from 2007 be adopted, and that these GWP values be 

included in the regulation as a table. 

 Response: Staff acknowledges the comment. ARB’s policy is to use the IPCC: 

1995 Second Assessment Report (IPCC, 1996) GWP values where they exist for 

a specific compound. If there is no SAR value, the 2007 Fourth Assessment 

Report (IPCC, 2007) GWP value shall be used. In the case where neither the 

SAR nor the FAR contain a GWP value for the specific compound, then the GWP 

value is assumed to be equal to the emission standard. These values are used 

to be consistent with other statewide and national Greenhouse Gas inventories 

(ARB, 2007c). 

c. Issue: Industry urges ARB to provide stable values over time while allowing 

updating as new materials are developed and new GWP values develop. 

 Response: See response to Issue #2 above. 

d. Issue: Industry urges ARB to ensure the proposed regulation (i.e., Table of 

GWPs) states clearly that compounds not listed as having a GWP value shall be 

considered to have a GWP value of 0. 

 Response: See response to Issue #2 above. 
Technical Support Document Chapter VI - 147 

REFERENCES 

1. Air Resources Board. 2007 Pressurized Gas Duster Survey Update. 

 February, 2008. (ARB, 2008c) 

2. Air Resources Board. Statewide Human Population Chart: Population and 

Vehicle Trends Report. April, 2008. (ARB, 2008d) 

3. Air Resources Board. ARB Compendium of Emission Factors and Methods to 

Support Mandatory Reporting of Greenhouse Gas Emissions. October, 2007. 

(ARB, 2007c) 

4. Air Resources Board. Initial Statement of Reasons for the Proposed 

Amendments to the California Aerosol Coating Products, Antiperspirants and 

Deodorants, and Consumer Products Regulations, Test Method 310, and 

Airborne Toxic Control Measure for Para-Dichlorobenzene Solid Air Fresheners 

and Toilet/Urinal Care Products. May 7, 2004 (ARB, 2004b) 

5. Air Resources Board. 2003 Consumer and Commercial Products Survey. 

 November, 2004. (ARB, 2004a) 

6. Consumer Specialty Products Association. Technology of Pressurized Gas 

Duster Products – Meeting with ARB staff. Andrew Steinman, Executive Vice 

President, Falcon Safety Products, Inc. March 5, 2008. (CSPA, 2008) 

7. DuPont Company in association with Falcon Safety Products. Fluorochemical

 Fluorochemicals Laboratory DuPont Company Technical Report, Subject: 

Cleaning Tests for Aerosol Dusting Aids (Dusters). December 1, 2004. Melodie 

Schweitzer, Janet Ludert, Bruce Hitches (DuPont Company). Brian Bilsback, 

Dermot McLeer (Falcon Safety Products). (Dupont & Falcon, 2004) 

8. Intergovernmental Panel on Climate Change. Forster, P., V. Ramaswamy, P. 

Artaxo, T. Berntsen, R. Betts, D.W. Fahey, J. Haywood, J. Lean, D.C. Lowe, G. 

Myhre, J. Nganga, R. Prinn, G. Raga, M. Schulz and R. Van Dorland, 2007: 

Changes in Atmospheric Constituents and in Radiative Forcing. In: Climate 

Change 2007: The Physical Science Basis. Contribution of Working Group I to 

the Fourth Assessment Report of the Intergovernmental Panel on Climate

 Change. [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, 

M.Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United 

Kingdom and New York, NY, USA. (IPCC, 2007) 

9. Intergovernmental Panel on Climate Change. Climate Change 1995, The 

Science of Climate Change; Contribution of Working Group I to the Second 

Assessment Report of the Intergovernmental Panel on Climate Change. [J.T. 

Houghton, L.G. Meira Filho, B.A. Callander, N. Harris, A. Kattenberg, and K. 

Maskell, (eds.)] Cambridge University Press. Cambridge, U.K. (IPCC, 1996)
Technical Support Document Chapter VII - 148 

VII. ECONOMIC IMPACTS

A. INTRODUCTION

 This Chapter provides our analysis of the estimated economic impacts we predict 

from implementation of the proposed VOC limits, one global warming potential (GWP) 

limit, and other proposed amendments to the regulation. In general, economic impact 

analyses are inherently imprecise by nature, given the unpredictable behavior of 

companies in a highly competitive market such as consumer products. While staff has 

quantified the economic impacts to the extent feasible, some projections are necessarily 

qualitative, and based on general observations and facts known about the consumer 

products industry. This analysis, therefore, serves to provide a general picture of the 

economic impacts typical businesses subject to the proposed limits might encounter. 

Individual companies may experience different impacts than projected. 

 The overall impacts are first summarized in Section B. A description of specific 

aspects of the economic impacts then follows in the sections listed below: 

C. Economic Impacts Analysis on California Businesses, Consumers, and 

Employment; 

D. Analysis of Potential Impacts to California State or Local Agencies; 

E. Analysis of the Cost-Effectiveness (CE) of the Proposed Limits; 

F. Analysis of the Impacts to Raw Materials Cost; 

G. Analysis of the Combined Impacts on Per-Unit Cost from Recurring and 

Nonrecurring Costs; 

H. Other Possible Economic Impacts from Proposed Amendments; and 

I. Mitigation of Potential Impacts through Additional Regulatory Flexibility. 

 It is important to note that we conducted this economic impacts analysis in 

accordance with the current legal requirements under the Administrative Procedure Act 

(APA). This analysis uses similar methodologies and assumptions as were used in the 

last four major consumer products rulemakings, the “Mid-Term Measures” regulations 

adopted by the Board in 1997, 1999, and in the 2004 and 2006 amendments to the 

regulation (ARB, 1997b; ARB, 1999; ARB, 2004b; ARB, 2006a). However, we have 

used updated methodologies to determine the high cost estimates for nonrecurring 

costs as was done in the 2004 and 2006 amendments (ARB, 2004b; ARB, 2006a). We 

have determined a likely high cost scenario specific to each category. See Section G of 

this Chapter for a detailed description of the nonrecurring cost determination 

methodology. 
Technical Support Document Chapter VII - 149 

B. SUMMARY OF FINDINGS

 Overall, most affected businesses will be able to absorb the costs (or will likely 

pass through some of the costs to the consumer) of the proposed limits and 

requirements with no significant adverse impacts on their profitability. This finding is 

indicated by the staff’s estimated change in “return on owner’s equity” (ROE) analysis. 

The analysis found that the overall change in ROE ranges from a low of 0.7 percent to a 

high of about 4.0 percent, with an average change in ROE of about 2.5 percent. 

However, the proposed measures may impose economic hardship on some businesses 

with very little or no margin of profitability. These businesses, if hard pressed, can seek 

relief under the variance provision of the consumer products regulation for extensions to 

the compliance dates. Such extensions may provide sufficient time to minimize the cost 

impacts to these businesses. Because the proposed measures would not significantly 

alter the profitability of most businesses, we do not expect a noticeable change in 

employment; business creation, elimination or expansion; and business 

competitiveness in California. We also found no significant adverse economic impacts 

to any local or State agencies. 

 Our analysis shows that the CE of the proposed amendments is higher than 

other existing VOC ARB regulatory programs. This is not surprising given that many 

categories proposed for regulation are smaller, in terms of emissions, and therefore, 

smaller emissions reductions result. We estimate the total overall CE of the proposed 

VOC limits and other requirements to be about $6.23 per pound of VOC reduced. We 

have also determined the CE of the proposed GHG limit relative to reducing carbon 

dioxide emissions. We estimate the CE of the proposed GHG limit for Pressurized Gas 

Dusters to be $0.22 per metric ton of CO2 equivalent (MT CO2e) reduced. 

 

 We estimate that the total cost incurred by industry to comply with this regulation 

is about $26 million per year for 10 years. These cost estimates are based on 

assumptions specific to each category depending on reformulation needs, and 

represent the mid-range of the cost estimates. Staff believes the mid-range costs are 

the most likely to be incurred by industry to comply with the proposed limits. For some 

categories, it was assumed that manufacturers would either drop certain products or 

undergo minor product formulation changes, and for other categories manufacturers 

would undergo complete production line overhaul and equipment replacement rather 

than simple re-tooling. 

 One way to estimate the potential change in cost to produce a product is to 

determine the change in raw materials cost, which generally has the biggest influence 

on product cost for most product categories. Our analysis indicates that reformulations 

to comply with the proposed limits can result in raw material changes ranging from 

negligible cost (net savings or no cost) up to a cost increase of about $0.63 per unit. 

The value of $0.63 represents the maximum, worst case, per-unit cost increase. This 

range compares favorably to the change in per unit cost projected for the Phase I and II, 

the Mid-Term Measures I and II regulations and the 2004 and 2006 Amendments. The 

analysis assumed the present cost for raw materials; these costs may be lower or 
Technical Support Document Chapter VII - 150 

higher at the time of the limit effective date depending on the formulations chosen by 

manufacturers and the future price of raw materials. To the extent that the projected 

cost savings or increases are ultimately passed on to the consumer, the actual retail 

price of products after the proposed limits become effective may be higher or lower than 

suggested by this analysis. 

 Even if all annualized nonrecurring costs (research and development, capital 

equipment purchases, etc.) and recurring raw material cost increases are factored into 

the affected products manufacturing costs, the potential increase in production per-unit 

costs are comparable to previous ARB consumer product rulemakings. The estimated 

per-unit cost increases from both annualized nonrecurring and annual recurring costs 

range from negligible cost (net savings or no cost) to about $2.05 per unit. The value of 

$2.05 represents the maximum, worst case, per-unit cost increase for a product which is 

typically packaged in a one gallon container. When averaged over the total number of 

unit sales in California of noncomplying products, (those that need to reformulate) the 

product weighted average cost increase is about $0.20 per unit. As noted before, these 

per unit cost increases compare favorably to the change in per unit cost projected for 

previous ARB consumer product rulemakings. 

Staff believes that the regulation cost and CE determination methodologies are 

quite conservative, and are thus in most cases, over-estimated. There are several 

factors that contribute to the over estimation of costs. The mid-range cost, (used to 

determine the overall cost and cost effectiveness of the regulation) is the average of the 

estimated high and low cost scenarios. The low cost scenario assumes that companies 

would choose the lowest cost reformulation pathway, making minor adjustments to a 

product’s formulation, or simply eliminating higher VOC products. We believe that most 

manufacturers would choose the lowest cost reformulation option. For the high cost 

scenario, it is assumed that there is significant research and development, and new 

equipment is needed to reformulate the product. We believe that few manufacturers 

would need to take the high cost reformulation approach. 

In the economic analysis, staff assumed that the VOC limits for Multi-purpose 

Lubricants would be the most challenging and costly to comply with. Staff separately 

calculated the estimated costs of reformulation for each of the proposed tiers of the 

Multi-purpose Lubricant proposal. Further, cost estimates were performed separately 

for aerosol and non-aerosol products respectively. The analysis shows that greater 

costs will be incurred during the first tier reformulation than the second tier 

reformulation. This results from the assumption that significant high end costs will be 

incurred in the first tier reformulation, but not all of these costs would necessarily be 

duplicated in the second tier reformulation. If major plant modifications or new 

equipment purchases are needed to meet either tier of the VOC limits, a manufacturer 

would likely choose to make these significant changes during one plant modification, 

rather than making significant more than once. In fact, certain companies may choose 

to reformulate only once, (i.e. reformulate to meet the second tier VOC limit before 

2013.) Regardless of whether this assumption is correct, we believe that it is 

appropriate to assume that high end reformulation costs will be incurred during either 
Technical Support Document Chapter VII - 151 

the first tier reformulation or the second tier reformulation, but not both. Either 

assumption, that higher costs would be incurred during a given tier relative to the other, 

would yield the same amount of total costs being incurred to meet both tiers. 

Another factor that can contribute to an over estimation of costs are the 

assumptions used for the raw ingredient costs. For the product categories for which 

VOC limits are proposed, we assumed that if the raw ingredients used in the 

reformulated product yielded a cost savings, the cost of the raw ingredients necessary 

to meet the new VOC limit is zero. This is a conservative assumption because for most 

product categories, there is more than one reformulation option. However, it is possible 

that a given manufacturer will choose more expensive ingredients to preserve certain 

specific product attributes. 

However, in the case of Pressurized Gas Dusters we assumed that reformulation 

would yield a raw ingredient savings, and incorporated the decreased cost into the 

overall cost estimate. We believe that this approach is appropriate because in order to 

comply with the proposed GWP limit for Pressurized Gas Dusters, there is only one 

identified reformulation pathway, replacing HFC-134a with HFC-152a. Because HFC152a is less expensive per pound that HFC-134a, it is appropriate that there would be a 

cost savings in virtually every case. Therefore, for Pressurized Gas Dusters, instead of 

assuming that the raw material cost is zero, the raw material cost savings was 

subtracted from the anticipated equipment and research and development costs of 

reformulation. 

C. ECONOMIC IMPACTS ANALYSIS ON CALIFORNIA BUSINESSES,

CONSUMERS, AND EMPLOYMENT

 1. Legal Requirements 

 Section 11346.3 of the Government Code requires State agencies to assess the 

potential for adverse economic impacts on California business enterprises and 

individuals when proposing to adopt or amend any administrative regulation. The 

assessment must include a consideration of the impact of the proposed regulation on 

California jobs; business expansion, elimination or creation; and the ability of California 

business to compete with businesses in other states. 

 Also, State agencies are required to estimate the cost or savings to any State or 

local agency and school district in accordance with instructions adopted by the 

Department of Finance. The estimate shall include any nondiscretionary cost or 

savings to local agencies and the cost or savings in federal funding to the State. 

2. Potential Impact on California Businesses 

 Overall, most affected businesses will be able to absorb the costs of the 

proposed measures with no significant adverse impacts on their profitability. It is likely 

that all cost will not be absorbed by businesses, by passing a portion through to 
Technical Support Document Chapter VII - 152 

consumers. However, the proposed measures may impose economic hardship on 

some businesses with very little or no margin of profitability. These businesses, if hard 

pressed, can seek relief under the variance provision of the consumer products 

regulation for extensions to their compliance dates. Such extensions may provide 

sufficient time to minimize the cost impacts to these businesses. Additional mitigation 

may be achieved by taking advantage of the compliance flexibility offered by the 

existing Innovative Product Provision (IPP) and the Alternative Control Plan (ACP) 

Regulation (see Subsection I of this Chapter). Because the change on the return on 

owners’ equity (ROE) has been determined to be quite low, the proposed measures 

would not significantly alter the profitability of most businesses. Further, we do not 

expect a noticeable change in employment; business creation, elimination or expansion; 

and business competitiveness in California. 

a. Return on Owners’ Equity

 This portion of the economic impacts analysis is based on a comparison of the 

ROE for affected businesses before and after inclusion of the cost to comply with the 

proposed requirements. The data used in this analysis are obtained from Dun and 

Bradstreet Industry Norms and Key Business Ratio (D&B, 2006-2007), the ARB’s 2003 

Consumer and Commercial Products Survey (2003 Survey), and the staff’s CE analysis 

discussed later in this Chapter. 

 b. Affected Businesses

 Any business which manufactures or markets consumer products subject to the 

proposed new limits and requirements can be directly affected by this regulation. Also 

potentially affected are businesses which supply raw materials or equipment to 

manufacturers or marketers, and those that distribute or sell consumer products in 

California. The focus of this analysis, however, will be on manufacturers, marketers, 

and distributors that are most affected by the proposed measures. 

 The consumer products subject to the proposed measures are manufactured, 

marketed, or distributed by a large number of companies worldwide. According to the 

2003 Survey, there are about 300 companies that market the affected products in 

California. These companies manufacture, market, and distribute a broad range of 

solvent, adhesive, household, and personal care products, including an estimated total 

of 2,366 complying and 1,535 noncomplying products (based on reported figures). Of 

the companies manufacturing these products, about 60 firms (mostly medium- or smallsized firms) are located in California. 

 These 300 companies fall primarily into 5 North American Industry Classification 

System codes (NAICS). A list of these industries which we have been able to identify is 

provided in Table VII-1. As shown in Table VII-1, the industries with the most 

noncomplying products fall under the NAICS for Lubricant Manufacturing; Adhesive 

Manufacturing; Polish and Other Sanitation Good Manufacturing, Toilet Preparation 
Technical Support Document Chapter VII - 153 

Manufacturing and All Other Miscellaneous Chemical Product and Preparation 

Manufacturing. 

Table VII-1 

Industries with Businesses Potentially Affected by the Proposed Limits 

NAICS* Industry

Number of 

Product 

Categories*

Number of 

Noncompliant 

Products**

Includes: 

324191 Lubricant Manufacturing 2 226 

Multi-Purpose Lubricant –

excluding solid & semisolid; 

Penetrant 

325520 Adhesive Manufacturing 2 271 

Sealant or Caulking Compound – 

Chemically Curing; 

 Sealant or Caulking Compound 

– Non-Chemically Curing 

325612

Polish & Other Sanitation Good 

Manufacturing 10 637 

Carpet/Upholstery Cleaner; 

Dusting Aid; Fabric Protectant; 

 Fabric Softener – Single Use 

Dryer Product; Floor 

Maintenance Product; Floor 

Polish or Wax; Glass Cleaner; 

Odor Remover/Eliminator; 

Pressurized Gas Duster; Spot 

Remover 

325620 Toilet Preparation Manufacturing 2 498 

Astringent/Toner (non-FDA 

regulated); Personal Fragrance 

Product – 20% or less fragrance 

325998

All Other Miscellaneous Chemical 

Product & Preparation 

Manufacturing 3 140 

Motor Vehicle Wash; 

Tire or Wheel Cleaner; 

Windshield Water Repellent 

 *As reported in the 2003 Consumer and Commercial Products Survey. (ARB, 2004a) 

** Some noncomplying products may relate to more than one NAICS code. Number of products may be different 

than those indicated in Table VII-5, due to calculations based on representative product size. 

 c. Study Approach

 This study covers 5 industries with at least 300 affected businesses. The 

approach used in evaluating the potential economic impact of the proposed measures 

on these businesses is as follows: 

 

(1) A typical business from each product category was selected from the 2003 

Survey respondents. 

(2) A range of compliance costs were estimated for each affected product 

category. The mid-range cost for each category was used in this analysis. 

(3) Compliance cost to a typical business was then estimated based on a 

weighted average of all product category costs in an affected industry. 

(4) Estimated cost was adjusted for federal and State taxes. 

(5) The Return on Owner’s equity (ROE) was calculated for each of these 

businesses by dividing the net profit by the net worth. The adjusted cost 

was then subtracted from net profit data. The results were used to 

calculate an adjusted ROE. The adjusted ROE was then compared with 
Technical Support Document Chapter VII - 154 

the ROE before the subtraction of the cost to determine the potential 

impact on the profitability of the business. 

 A reduction of more than 10 percent in profitability is considered to indicate a 

potential for significant adverse economic impacts. This value has been used 

consistently by the ARB staff to determine impact severity (ARB,1990c; ARB, 1991a; 

ARB, 1995; ARB, 1997b; ARB, 1999; ARB, 2004b; and ARB, 2006a). This threshold is 

consistent with the thresholds used by the U.S. EPA. 

d. Assumptions

 This study uses 2004-2006 Dun and Bradstreet financial data for a nationwide 

typical business in each affected industry except for Toilet Preparation Manufacturing 

and All Other Miscellaneous Chemical Product and Preparation manufacturing where 

2005 and 2004-2005 Dun and Bradstreet financial data were used, respectively, due to 

lack of complete financial data. These data were used to calculate the ROEs before 

and after the subtraction of the compliance costs for a typical business in each industry 

listed in Table VII-1. The calculations were based on the following assumptions: 

(1) A typical business on a nationwide basis in each industry is representative 

of a typical California business in that industry; 

(2) All affected businesses were subject to federal and State tax rates of 

35 percent and 9.3 percent respectively; and 

(3) Affected businesses are not able to increase the prices of their products, 

nor can they lower their costs of doing business through short-term costcutting measures. 

 Given the limitation of available data, staff believes these assumptions are 

reasonable for most businesses at least in the short run; however, they may not be 

applicable to all businesses. 

 e. Results

 Typical California businesses are affected by the proposed new limits to the 

extent that the implementation of these requirements would change their profitability. 

Based on our assessment of the proposed limits’ CE (see Subsection E of this 

Chapter), we estimate the per-business compliance costs to range from about $1,700

(low cost for typical Penetrant manufacturer) to about $54,000 per year (high cost for 

typical Multi-Purpose Lubricant manufacturer) as shown in Table VII-2. Table VII-7 also 

shows total mid-range, per product cost of about $14,000 per year.
Technical Support Document Chapter VII - 155 

Table VII-2 

Estimated Total Impacts to Businesses from Both Annualized Nonrecurring and 

Annual Recurring Costs 
Technical Support Document Chapter VII - 156 

 Using ROE to measure profitability, we found that the average ROE of sample 

businesses in affected industries declined by about 2.5 percent as shown in 

Table VII-3. This represents a minor change in the average profitability of typical 

businesses in California. 

Table VII-3 

Changes in Return on Owner’s Equity (ROEs) for Typical Businesses in 

Affected Industries

NAICS* Industry % Change 

in ROE

324191 Lubricant Manufacturing 2.8 

325520 Adhesive Manufacturing 4.0 

325612 Polish & Other Sanitation Good Manufacturing 2.8 

325620 Toilet Preparation Manufacturing 2.4 

325998 All Other Miscellaneous Chemical Product & Preparation 

Manufacturing 

0.7 

Average 2.5 

Note: Changes in ROE mean change or difference; all changes in ROEs shown are negative (i.e., shows 

a decline in profitability). 

 

 As shown in Table VII-3, the projected change in profitability of typical 

businesses in the 5 affected industries varies by industry sector. Within the NAICS 

shown, the predicted change (decline) in profitability of a typical business ranged from a 

high of about 4.0 percent to a low of 0.7 percent. This variation in the impact of the 

proposed measures can be attributed primarily to two factors. First, some businesses 

incur higher costs due to the type of products or the number of noncompliant products 

they manufacture or market. For instance, the estimated annualized costs for typical 

businesses in each affected industry ranged from a high of approximately $35,000 to a 

low of about $5,000. These values are a product weighted average cost of the 

respective annualized costs for all products. Second, the performance of businesses 

may differ from year to year. Hence, the financial data used may not be representative 

of an average-year performance for some businesses. 

 The potential impacts to businesses’ ROEs may be overestimated for the 

following reasons. First, annualized costs of compliance are estimated using, in part, 

the current prices of raw materials. Raw material prices usually tend to rise as oil prices 

increase, but tend to fall as higher demand for these materials induces economy of 

scale production in the long run. Second, affected businesses would not absorb all of 

the increase in their costs of doing business. They may be able to either pass some of 

the cost on to consumers in the form of higher prices, reduce their costs, or do both. 

 In this analysis, as in 2004 and 2006, we allocated nonrecurring reformulation 

costs only to the noncomplying products. 
Technical Support Document Chapter VII - 157 

 3. Potential Impact on Business Creation, Elimination or Expansion 

 The proposed measures would have no noticeable impact on the status of 

California businesses. This is because the reformulation costs are not expected to 

impose a significant impact on the profitability of businesses in California. However, 

some small businesses with little or no margin of profitability may lack the financial 

resources to reformulate their products on a timely basis. Should the proposed 

measures impose significant hardship on these businesses, temporary relief in the form 

of a compliance date extension under the variance provision may be warranted. 

 On the other hand, the proposed measures may provide business opportunities 

for some California businesses or result in the creation of new businesses. California 

businesses which supply raw materials and equipment or provide consulting services to 

affected industries may benefit from increased industry spending on reformulation. 

 4. Potential Impact on Business Competitiveness 

The proposed measures would have no significant impact on the ability of 

California businesses to compete with businesses in other states. Because the 

proposed measures would apply to all businesses that manufacture or market certain 

consumer products regardless of their location, the staff’s proposal should not present 

any economic disadvantages specific to California businesses. 

 Nonetheless, the proposed measures may have an adverse impact on the 

competitive position of some small, marginal businesses in California if these 

businesses lack resources to develop commercially acceptable products in a timely 

manner. As stated above, such impacts can be mitigated to a degree with a justifiable 

compliance extension under the variance provision of the Consumer Products 

Regulation, or through additional regulatory flexibility afforded by the IPP or the ACP 

Regulation (see Subsection H). 

 5. Potential Impact on California Consumers 

The potential impact of the proposed measures on consumers depends upon the ability 

of affected businesses to pass on the cost increases to consumers. In the short run, 

competitive market forces may prevent businesses from passing their cost increases on 

to consumers. Thus, we do not expect a significant change in retail prices in the short 

run. In the long run, however, if businesses are unable to bring down their costs of 

doing business they will likely pass their cost increases on to consumers. 

 To estimate the price increase, we adjusted per unit compliance costs for each 

affected industry by its profit margin as provided by Dun and Bradstreet. Assuming 

affected industries will pass on the entire compliance costs to consumers in terms of 

higher prices, we estimate the average price of a product would increase by about 

$0.03 per unit. Product price increases, however, would vary from industry to industry. 

They would range from a low of $0.01 per unit of the products sold by the Personal 
Technical Support Document Chapter VII - 158 

Care Products Industry to a high of about $0.05 per unit of the products sold by 

Household Care Products. 

 The proposed measures may also affect consumers adversely if they result in 

reduced performance attributes of the products. However, this scenario is unlikely to 

occur for the following reasons. First, for nearly every proposed limit, there are already 

complying products that represent significant market share in many of their respective 

categories. Thus, the industry already has the technology to manufacture compliant 

products that satisfy consumers. Second, marketers are unlikely to introduce a product 

which does not meet their consumers’ expectations. This is because such an 

introduction would be damaging not only to the product sale, but also to the sale of 

other products sold under the same brand name (impairing so-called “brand loyalty”). 

Finally, the Board has provided flexibility, under the existing consumer products 

program, to businesses whose situations warrant an extension to their compliance 

dates. For companies that can justify such variances, the additional time may afford 

more opportunity to explore different formulation, cost-cutting, performance-enhancing, 

or other marketing strategies which can help make the transition to new complying 

products nearly transparent to consumers. 

 6. Potential Impact on California Employment 

 The proposed measures are not expected to cause a noticeable change in 

California employment and payroll. According to the U.S. Department of Commerce, 

California employment in industries affected by the proposed measures was 13,885 in 

2005, as shown in Table VII-4, or about 9.7 percent of national employment in the 

affected industries. This represents less than 1 percent of manufacturing employment 

in California. These employees working in the 458 establishments generated about 

$667 million in payroll, or about 9.4 percent of national payroll in the affected industries. 

This also accounts for less than 1 percent of the total California manufacturing payroll in 

2005. 

D. ANALYSIS OF POTENTIAL IMPACTS TO CALIFORNIA STATE OR LOCAL 

AGENCIES 

We have identified two State agencies that could/or would be impacted. The 

California Prison Industry Authority (PIA) manufactures and markets consumer products 

for use in State service. This is the only State agency we are aware of that makes 

consumer products. The PIA manufactures a drain maintainer, which could be subject 

to the proposed six percent limit for non-aerosol Odor Remover/Eliminator. This 

product, if subject, would meet the proposed new limit for Odor Removers/Eliminators. 

The PIA also sells bar soaps, powder bleaches, liquid glass cleaners, liquid 

multipurpose cleaner and degreasers, floor finishes, and liquid and powder detergents 

(PIA, 2008). The proposed measures do not affect these categories and, as such, will 

not have an impact on the PIA. 
Technical Support Document Chapter VII - 159 

Table VII-4 

California Employment and Payroll in Affected Industries 

NAICS

Number of Employees Payroll

 California CA Share as % of US California 

 (million in 2005$)

CA Share as % 

of US 

324191 720 5.4 39,807 5.5 

325520 2,452 11.9 130,584 12.4 

325612 1,081 6.0 44,846 5.2 

325620 7,542 13.3 346,387 13.2 

325998 2,090 5.9 105,257 5.9 

Total 13,885 9.7 666,881 9.4 

Source: (U.S. Census, 2005) 

 The Air Resources Board (ARB) would have costs associated with adoption of 

the proposed amendments. Adoption of the amendments would necessitate an 

increase in ARB staff to properly enforce the Consumer Products Regulation. These 

proposed amendments are setting new limits for a number of previously unregulated 

categories. It has been determined that to enforce these new limits, two ARB staff will 

be needed. This would result in an increased cost to the State of approximately 

$300,000 per year. 

E. ANALYSIS OF THE COST-EFFECTIVENESS (CE) OF THE PROPOSED 

LIMITS

 1. Introduction 

 In the following analysis, we evaluated the anticipated CE of the proposed new 

limits. Such an evaluation allows us to compare the efficiency of the proposed limits in 

reducing a pound of VOC or a metric ton of CO2e relative to other existing regulatory 

programs. To do this, we applied a well-established methodology for converting 

compliance costs, both nonrecurring and recurring, to an annual basis. We then report 

the ratio of the annualized costs to the annual emission reductions in terms of “dollars 

(to be) spent per pound of VOC reduced or metric ton of CO2e reduced in the case of 

Pressurized Gas Duster. For perspective, we compare the estimated cost-effectiveness 

of the proposed limits to the cost-effectiveness of other ARB regulations and control 

measures. 
Technical Support Document Chapter VII - 160 

2. Methodology 

 The CE of a reduction strategy is generally defined as the ratio of total dollars to 

be spent to comply with the strategy (as an annual cost) to the mass reduction of the 

pollutant(s) to be achieved by complying with that strategy (in annual pounds or metric 

tons). Annual costs include annualized nonrecurring fixed costs (e.g., total research 

and development (R&D), product and consumer testing, equipment 

purchases/modifications, etc.) and annual recurring costs (e.g., raw materials, labeling, 

packaging, etc.). 

 

 We annualized nonrecurring fixed costs using the Capital Recovery Method, as 

recommended under guidelines issued by the California Environmental Protection 

Agency (Cal/EPA). Using this method, we multiply the estimated total fixed costs to 

comply with the limits by the Capital Recovery Factor (CRF) to convert these costs into 

equal annual payments over a project horizon (i.e., the projected useful life of the 

investment) at a discount rate. We then sum the annualized fixed costs with the annual 

recurring costs and divide that sum by the annual emission 

reductions to calculate the cost-effectiveness of the regulation, as shown by the 

following general equation: 

Cost-Effectiveness 

= (Annualized Fixed Costs) + (Annual Recurring Cost) 

 (Annual Mass Reduction in VOC) 

 

 

where: 

Annualized Fixed Costs = 

 

 i(1+i)n/((1+i)n-1) = Capital Recovery Factor (CRF) 

 i = discount interest rate over project horizon, % 

 n = number of years in project horizon 

 Fixed Costs = total nonrecurring cost per product category 

 = (Nonrecurring Cost per Product) x (Total 

Noncompliant Products in the Category)

 As shown by the raw materials cost analyses in Appendix D, a convenient 

method for estimating the annual recurring cost portion of overall cost-effectiveness is to 

separate Equation (1) into two fractions, one for the nonrecurring costs and one for the 

recurring costs. It can then be shown that the CE fraction for recurring costs can be 

simplified and calculated as follows: 

- 1

n

(1 i)+

n

(1 i i)+

(Fixed Costs) x 

(1) 

(2) 
Technical Support Document Chapter VII - 161 

Annual 

Recurring Costs CE= 

where, 

 

 Baseline Materials Cost = cost of raw materials for product before 

reformulation to the proposed limit $/lb product 

 Baseline VOC Content = product VOC weight fraction before 

reformulation to limit, lb VOC/lb product 

 Compliant Materials Cost = cost of raw materials for compliant product, $/lb 

product 

 Compliant VOC Content = product VOC weight fraction of compliant 

product, lb VOC/lb product. 

 In the case of Pressurized Gas Duster, the calculations are similar except that in 

place of VOC content, product GWP value content is used. To use Equation (3), staff 

determined typical VOC or GWP value content of both compliant and noncompliant 

products in each of the product categories/subcategories, based on sales data and the 

speciated formulations as reported by manufacturers in the ARB’s 2003 Survey. To the 

extent feasible, staff determined the detailed formulations that most closely reflect the 

“typical” compliant and noncompliant VOC or GWP value contents. These formulations, 

in turn, were designated as compliant and baseline formulations, respectively (See 

Appendix D). 

 For most ingredients, we used the most recent, distributor-level bulk prices from 

the ICIS Chemical Business web site (ICIS, 2008). Costs for other ingredients were 

obtained from discussions with chemical suppliers, or from web searches of analytical 

grade chemicals. All of these data sources were used to calculate the baseline and 

compliant material costs based on these designated formulations shown in Appendix D. 

Inorganic compounds were assigned a low and high cost of $0.09 and $0.91 per pound 

based on the costs found of the most common inorganic compounds found in the 

product categories. Other unspecified ingredients or ingredients for which prices were 

unknown were grouped into an “all others” classification and assigned a default low and 

high cost of $3.50 and $7.00 per pound, respectively (ARB, 1997c). These analyses 

are shown in Appendix D and discussed in more detail in “Analysis of Impacts to Raw 

Materials Cost” later in this section. 

 We used a very similar methodology to determine the CE of the proposal to 

reduce the potency of greenhouse gas emissions from Pressurized Gas Dusters, as 

described above. Instead of evaluating costs relative to VOC reductions, for 

Pressurized Gas Dusters we evaluated the costs of reducing GHG emissions equivalent 

to reducing a metric ton of carbon dioxide. 

(BaselineVOC Content) - (CompliantVOC Content)

(Compliant Materials Cost) - (Baseline Materials Cost)

(3) 
Technical Support Document Chapter VII - 162 

 3. Assumptions 

 We calculated the CE with an assumed project horizon of 10 years, a commonly 

cited period for an investment’s useful lifetime in the chemical processing industry. We 

also assumed a fixed interest rate of 10 percent throughout the project horizon. These 

assumptions are conservative and constitute standard practice in CE analyses of air 

pollution regulations, including previous consumer product rulemakings. Based on 

these assumptions, the Capital Recovery Factor (CRF) is 0.16275. 

 For this rulemaking, we assumed products reformulated to meet the proposed 

limits will be marketed throughout the U.S. by national marketers (ARB, 1997b). We 

earlier determined that businesses generally formulate for, and distribute to the entire 

nation, products compliant with our regulations rather than incurring the additional cost 

of setting up a California specific product distribution system. We believe the same 

strategy will be employed by companies subject to the proposed new limits. We, 

therefore, assumed in the Midterm II analysis in 1999 that, for the annualized fixed cost 

portion of Equation (1), it was appropriate to use the fixed cost for national production 

divided by the national emission reductions. 

 However, an alternative but equivalent approach, which we used in the 2004 and 

2006 analyses, and in this analysis, is to report the California-apportioned (by 

population) annualized fixed cost divided by the California-apportioned emission 

reductions. To illustrate, a manufacturer may need to install $10 million worth of 

equipment to produce its national sales volume of products compliant with the proposed 

limits. However, if the company were to produce a California and 49-state product, the 

company may only need to install $1 million worth of equipment to produce unit sales 

sufficient for the smaller California market. Using this alternative approach, we 

discounted the total fixed costs for producing national sales volumes by the Californiaapportionment factor (i.e., the current ratio of California to U.S. population, or 

12.5 percent (CA DOF, 2007)), which we then divided by the California-only emission 

reductions. It is important to note that, while both of the approaches described above -- 

the national marketing and California-only approaches -- reach the same conclusion, 

they do so for different reasons as discussed above. 

 For the annual recurring costs, we assumed compliant reformulations would 

result in cost changes as a result of changes in a product’s raw materials and their 

associated prices. Changes in packaging, labeling, distribution and other recurring 

costs were assumed to be negligible relative to baseline levels of these costs. This 

assumption is based on our previous regulatory experiences. To illustrate, in 1996, we 

conducted a comprehensive technical assessment of the 55 percent by weight VOC 

hairspray limit, which required extensive reformulations to existing products (ARB, 

1997c). The hairspray limit is generally considered to be among the most challenging of 

the consumer product limits; it likely resulted in more changes to the regulated product, 

relative to pre-regulatory products, than any other VOC limit. However, our assessment 

found that changes to recurring costs other than hairspray raw material costs were 

expected to be negligible (ARB, 1997c). Based on this finding and because the 
Technical Support Document Chapter VII - 163 

proposed new limits are designed to preserve product forms, we believe our 

assumptions regarding the recurring costs are reasonable. 

 4. Results 

 A review of relevant technical literature and industry trade journals provided little 

information that we could use to estimate costs directly. This is not surprising, because 

the consumer products industry is very competitive, and production cost data specific to 

a company are closely-guarded trade secrets. We have received significant comments 

regarding our assumptions for fixed costs from specific interested parties. We worked 

with these industry representatives to obtain new, updated, substantiated fixed cost 

data. The information we received generally confirms our cost assumptions to be 

correct. We therefore developed estimates for the nonrecurring costs based on 

analogous costs reported by ARB staff for the Phase II consumer products rulemaking 

(Id, Appendix D1). The Phase II nonrecurring costs are applicable for this analysis 

since they were based on staff’s detailed estimates of labor, research and development, 

equipment purchase, and other costs involved in product reformulations for generic 

household, automotive, and personal care categories, all of which are impacted by 

proposed limits. This is the same approach we used for the 1997 Mid-Term Measures 

rulemaking, the 1999 Mid-Term Measures II rulemaking, and the 2004 and 2006 

rulemakings. 

 The Phase II nonrecurring investment costs, reported in 1991 dollars, were 

adjusted to 2007 dollars using a well-established method of ratioing chemical 

engineering plant cost indices as follows (Peters and Timmerhaus, 1980): 

)4(

C.E.1991 Index

C.E. 2007 Index

10

Non Recurring Costs (in 1991dollars) Non - Recurring Costs (in 2007 dollars) ×−

=

where, 

 CE 2007 index = 2007 Chemical Engineering Plant Cost Index = 525.0

 (Chemical Engineering, April 2008). 

 CE 1991 index = 1991 Chemical Engineering Plant Cost Index = 361.3 

 (Chemical Engineering, April 1997). 

 

 We believe the original Phase II cost estimates were beneficial at the time of the 

rulemaking for predicting the costs to comply with those limits. However, it was 

discovered during Midterm II that these original cost estimates grossly overestimated 

the true nonrecurring costs for Phase II by a factor of ten (ARB, 1999, op cit. at Vol II, 

Chapter VII, Page 211). We therefore estimated the nonrecurring costs for the 

proposed new limits by adjusting the Phase II estimates to be consistent as shown in 

Equation (4). 
Technical Support Document Chapter VII - 164 

 Table VII-5 shows our estimates for per-product and total annualized 

nonrecurring costs for each of the product categories/subcategories subject to the 

proposed limits. 

 As shown, we project a per-product annualized nonrecurring cost ranging from a

low of about $8,000 to a high of about $243,000. With 1,535 noncompliant products 

that would need to be reformulated, the overall total annualized fixed cost to industry is 

projected to range from about $4 million to just about $16 million dollars per year, with a 

general breakdown of this range as follows: automotive care products (2 percent), 

household care products (72 percent), personal care products (16 percent) and 

adhesives (10 percent). 

 Our analysis shows that the CE of the proposed requirements is higher than the 

CE of other rulemakings for consumer products or the Suggested Control Measure for 

Architectural and Industrial Maintenance Coatings. We estimate the total overall CE of 

the initial proposed limits and other requirements to be about $6.23 per pound of VOC 

reduced, and about $0.22 per metric ton of CO2 equivalent reduced. 

 It should be noted that a contributing factor to the total average cost per pound of 

VOC reduced is that the VOC emission reductions achieved from some of the proposed 

limits specific to individual categories may be quite low. A limit may have been set 

largely as a cap, with the few reductions being achieved resulting in a few VOC 

reductions and a low CE. While the costs incurred by manufacturers to reformulate 

small categories is not excessive, when those costs are apportioned to a relatively small 

emission reduction, the CE may appear low (high cost per pound of VOC reduced). 

Therefore, when presenting the overall CE of the proposal, one should consider the 

effect of relatively low CE in some categories.

 
Technical Support Document Chapter VII - 165 

Table VII-5 

Estimated Total Nonrecurring Fixed Costs to Comply with Proposed Limits 

 
Technical Support Document Chapter VII - 166 

 Table VII-6 shows a comparison of the CE for the proposed limits relative to 

other ARB consumer product regulations and control measures. As expected, costs for 

the proposed amendments are higher than other recent consumer products measures. 

These higher costs can be attributed to regulating smaller emitting and/or more 

challenging categories than in the past. 

Table VII-6 

Comparison of Cost-Effectiveness for ARB Consumer Product 

Regulations/Measures 

Regulation/Control Measure 

Cost-Effectiveness 

(Dollars per Pound VOC Reduced)

2008 Amendments $6.23 

2006 Amendments1$2.35 

2004 Amendments1$2.01 to $2.34 

Aerosol Adhesives2$6.00 

Architectural and Industrial Maintenance 

Coatings3

$1.12 

 1 Categories where reduction of toxic air contaminant emissions occurred were included (ARB, 

2004b; ARB, 2006a). 

2 ARB, 2000c. 

3 Suggested Control Measure, developed with the California Air Pollution Control Officers 

Association (ARB, 2007i). 

F. ANALYSIS OF THE IMPACTS TO RAW MATERIALS COST 

1. Introduction 

 As part of the economic impact analysis, we evaluated the expected cost impacts 

from the proposed limits on raw material costs. As stated previously, the raw material 

costs generally constitute the major portion of the compliance costs for most categories. 

However, evaluating the impacts to raw material costs provides only an indicator of 

possible impacts to the retail prices of the affected products (assuming the cost impacts 

are passed on partially or fully to consumers). Because of unpredictable factors such 

as the highly competitive nature of the consumer products market, it is not possible to 

accurately predict the final retail price of products that will comply with the proposed 

limits when they become effective. To the extent the cost impacts are passed on to 

consumers, the final retail prices may be lower or higher than suggested by this 

analysis. 

 2. Methodology 

 As discussed previously, staff determined the formulations which most closely 

reflect the “typical” compliant and noncompliant VOC contents. These formulations, in 

turn, were designated as compliant and non-compliant formulations, respectively. 
Technical Support Document Chapter VII - 167 

Distributor-level ingredient prices from ICIS Chemical Business website (ICIS, 2008), 

and chemical materials distributors were used to calculate the baseline and compliant 

material costs for these formulations. Sources of cost information were used for 

selected ingredients as discussed previously. Other than compounds specifically 

requested, the 2003 Survey did not ask for specific ingredient details for exempt, 

fragrance, some low vapor pressure VOCs, and inorganic compounds. Unspecified 

ingredients or ingredients for which prices were unknown were grouped into an “all 

others” classification and assigned a default low and high cost of $3.50 and $7.00 per 

pound, respectively (ARB, 1997b), with the exception of fragrance which was assumed 

to have a default low and high cost of $5.00 and $10.00 per pound respectively. 

However, inorganic compounds tend to be less expensive and using the default low and 

high cost would not give an accurate representation of inorganic compound cost. 

Therefore inorganic compounds were assigned a low and high cost of $0.09 and $0.91 

per pound based on the costs found of the most common inorganic compounds found in 

the product categories. These analyses and the formulations evaluated (with individual 

weight fractions and unit prices per pound) are shown as cost spreadsheets in 

Appendix D. While these formulations may not reflect the exact composition of existing 

noncompliant products and compliant products that will be marketed, we believe they 

are reasonably representative for the purposes of this analysis. 

 3. Assumptions 

 As noted previously, we assumed changes in packaging, labeling, distribution 

and other recurring costs to be negligible relative to baseline levels of these costs (ARB, 

1997b. The most likely pathway for reformulation was assumed for noncompliant 

products. Despite this assumption, alternative formulations may allow lower-cost 

compliant products than shown in our analysis. 

 4. Results 

 As shown in Table VII-7, the anticipated raw materials cost changes range from 

no cost (net savings or no cost) to about $0.63 increase per unit (for Floor Polish or 

Wax – Wood Floor Wax).
Technical Support Document Chapter VII - 168 

Table VII-7 

Estimated Impacts to Raw Materials Cost Per Unit 
Technical Support Document Chapter VII - 169 

Table VII-7 

Estimated Impacts to Raw Materials Cost Per Unit (continued) 
Technical Support Document Chapter VII - 170 

 Table VII-8 shows a comparison of the impacts to raw materials cost under the 

proposed limits relative to those of other ARB consumer product regulations. 

Table VII-8 

Comparison of Raw Materials Cost Impacts for the Proposed Limits and Other 

ARB Consumer Product Regulations (unadjusted dollars) 

Regulation 

Cost Impacts 

(Dollars per Unit of Product) 

2008 Amendments $0.00 to $0.63 

2006 Amendments1$0.00 to $0.44 

2004 Amendments2$0.00 to $0.77 

Mid-Term Measures II3$0.00 to $0.25 

Aerosol Adhesives4$0.00 to $0.60 

Architectural and Industrial Maintenance 

Coatings5 

$0.00 to $4.40 

1. (ARB, 2006a) 

2. (ARB, 2004b) 

3. (ARB, 1999) 

4. (ARB, 2000c) 

5. Suggested Control Measure, developed with the California Air Pollution Control Officers 

Association (ARB, 2007i) 

G. ANALYSIS OF THE COMBINED IMPACTS ON PER-UNIT COST FROM 

RECURRING AND NONRECURRING COSTS

 1. Introduction 

 In this analysis, we evaluated the combined impacts of both recurring (i.e., raw 

materials costs) and nonrecurring costs from the proposed limits on per-unit costs. 

Although the raw material costs generally constitute the major portion of the compliance 

costs, in some categories, the nonrecurring (fixed) cost was the major contributor. In 

performing this analysis, we used the fixed costs, raw material costs, assumptions, and 

other facts discussed previously. 

 2. Methodology 

 

 Nonrecurring Costs

 Historically, staff has considered a variety of costs in its calculations to determine 

the costs of complying with proposed VOC limits affecting consumer products. In the 

1991 Phase II Consumer Products Rulemaking, staff developed a methodology to 

determine nonrecurring reformulation costs (non-raw material costs) for proposed VOC 

limits. These costs were broken down by each process needed for reformulation to 

occur (ARB, 1991a). It was subsequently determined through a thorough cost analysis 
Technical Support Document Chapter VII - 171 

of the reformulations that was done to comply with the 55 percent by weight VOC limit 

for hairspray, that these costs were overestimated by a factor of 10. It was widely 

believed that the 55 percent by weight VOC limit for hairspray represented the most 

aggressive, challenging, and expensive reformulation that had been required by the 

Consumer Products Regulations. Therefore, subsequent cost analyses grew the 

factors by the Chemical Engineering Plant Cost Index then divided these reformulation 

factors by 10 (see Section C, Equation (4)). 

 There are many variables in producing a product for market, and assumptions 

about those variables will greatly affect the outcome of any cost analysis. For each 

assumption, a test of “reasonableness” was applied to determine if this was a likely 

approach to take or if the event had a high probability of occurring. Results were also 

compared to data provided by other agencies and industry to verify that the numbers 

are “reasonable.” Significant input regarding reformulation costs have been provided by 

industry representatives. In all cases, only new or additional costs were considered. 

Costs were not considered that would have been expected in the normal course of 

business if the regulation had not been in effect. 

 To estimate nonrecurring cost numbers, the staff considered two cost estimate 

approaches for each product category, one for low cost, and one for high cost, with a 

different set of assumptions for each approach. To further refine the analyses, the 

product categories proposed for regulation were grouped under “adhesives,” 

“automotive,” “household care,” and “personal care” to better reflect the impact on each 

category. 

 3. Approach 

 For a systematic approach to the cost analysis, the entire time from initial 

statement of development goals to final delivery of the new product to the marketplace 

shelves was divided into eight phases. The phases are: product development, 

including reformulation and development of a new delivery system if necessary; stability 

testing; efficacy testing; safety testing; labeling modification; registration with regulatory 

agencies, if necessary; manufacturing change; and marketing. The length of time in 

each phase was estimated based on an industry analysis of 80 new product 

innovations. Most of the phases occur in sequence; however, there is some time 

overlap in each phase. 

 

 Next, estimated personnel resources were allocated against each phase 

considering the most probable types of skills needed including general engineering; 

technician; drafting; packaging engineering; specification engineering; model making; 

chemical engineering; technical publication; production support; quality assurance; 

marketing; warehousing; word processing; and clerical. For high cost elements, 

additional personnel were allocated to each phase. 

 After the personnel costs were determined, additional cost elements were 

considered at each phase and added as appropriate. These cost elements are facility; 

equipment; tool; jig; fixture and miscellaneous materials handling equipment; purchased 
Technical Support Document Chapter VII - 172 

material; packaging; distribution; warehousing; technical data; research studies and 

tests; promotional literature; residual inventory and disposal; consumer tests; general 

and administrative expense; patent; registration fees; and computer support. The result 

of these considerations is a per-product cost for developing a reformulated product and 

putting it on the market. 

 4. Assumptions 

 The staff used different assumptions for the low and high cost analyses, and 

considered the specific likelihood that each of the cost elements would occur for each 

product category individually. In reviewing the 2003 Survey, staff found that many of 

the products which would technically be noncomplying are within a couple of 

percentage points of VOC weight from being in compliance with the standard. These 

products may require only minor modification to their current formulation to come into 

compliance. Therefore, for the low cost analysis no major costs were added for 

changing delivery systems or other product attributes. 

 In addition, it is common that large companies having significant market-share 

and broad product lines offer both low VOC complying products and higher VOC 

noncomplying products. In many cases, relatively low costs would be incurred where 

these companies could increase sales and distribution of complying products and 

discontinue noncomplying products. 

 If products do not change significantly, it is assumed that major retooling of 

manufacturing equipment would not be required, technical data changes would be 

minor, and the change in marketing costs would be small. It was also assumed that 

these reformulated products would be marketed nationally. 

 For the high cost approach, each category was analyzed individually to 

determine which of the elements, discussed above, manufacturers would likely include 

in their reformulation efforts. High costs for specific steps of the reformulation process 

were only included in the cost analysis where staff believed they were likely to occur. 

If staff believed a markedly different product would be needed to comply with the 

proposed limit, such as a new delivery system, then high personnel and capital 

resources, especially in product development and manufacturing changes, were 

assumed. In addition, a new delivery system would require investment for prototypes, 

new filling machines training, and technical data, so these high costs were also included 

in these scenarios. Additional costs were also added for packaging, distribution and 

warehousing. In areas where it was expected that little or no reformulation would occur, 

or that the cost of reformulation would be minimal, the value for low cost was used 

(Tire or Wheel Cleaner, Motor Vehicle Wash). 

 For especially challenging limits, it was assumed for the high cost approach that, 

because of a markedly different product, there would also be additional marketing costs, 

including research studies and tests, promotional literature, and consumer tests. These 

costs vary by the type of product, with household products typically having a larger 
Technical Support Document Chapter VII - 173 

expense in this area. The cost analysis did not include the costs for an extensive 

advertising campaign. New products are regularly brought onto the market, and the 

advertising for a new product, whether reformulated or not, would replace the 

advertising for the existing product, and would be a normal cost. It was assumed that 

the new product would be marketed nationally. 

 The staff also recognized that development of a new product does not occur in 

isolation. Few companies have only one product line; for those that have more than 

one product line, the product lines can be very similar. Development and production 

tasks, from the initial concept through marketing, would be proceeding simultaneously 

on more than one product line, with a transfer of information and work-sharing between 

the products. For these companies, this “technology transfer” would substantially 

reduce the cost of developing and marketing a new product on a per product basis. 

For categories where the majority of products were held by a few companies it was 

assumed that this “technology transfer” would occur, and high costs adjusted 

accordingly. 

 Therefore, staff has considered only nonrecurring costs that are likely to occur on 

a per category basis. If it was determined that for a majority of products in the category, 

the most likely scenario was that only minor changes to the product’s reformulation 

were necessary to comply with the new proposed limit then only the lower end of the 

nonrecurring cost was included. For some categories, it was appropriate, based on the 

variety of products and reformulation approaches needed to meet the proposed limit, 

that certain high cost factors be included in the analysis, but not others, on a case-bycase basis. We believe that this approach gives a more realistic estimate of the costs of 

a given limit. 

 5. Results 

 As shown in Table VII-9, the combined fixed and raw material cost changes to 

per-unit production costs ranged from no cost increase (net savings or no cost for 

various categories) to about $2.05 per unit (for 1 gallon of non-aerosol Penetrant). 

Averaged over all of the noncomplying products affected by the proposed limits and 

other requirements, the product-weighted average cost increase is about $0.20 per unit. 

H. OTHER POSSIBLE ECONOMIC IMPACTS FROM PROPOSED 

AMENDMENTS 

Beyond the VOC and GHG limits, there are other proposed amendments to the 

Consumer Products Regulation, some of which may have a potential economic impact 

on affected businesses. While we do not expect any significant economic impact from 

any of the proposals, it is possible that there could be some increased cost to business 

resulting from proposed changes. 

 Some products that do not need to reformulate, because they already comply 

with the VOC limits, may need to relabel because of other proposed changes to the 

regulation. 
Technical Support Document Chapter VII - 174 

Table VII-9 

Estimated Per-Unit Cost Increases from Both Annualized Nonrecurring and 

Annual Recurring Costs 
Technical Support Document Chapter VII - 175 

 We expect that businesses will benefit economically from the exemption of HFE 

7200 from the definition of VOC, because it could offer more formulation flexibility. 

There may be minimal reformulation costs incurred by those very few companies 

that use chlorinated solvents in those categories for which staff has proposed to prohibit 

the toxic compounds. 

I. MITIGATION OF POTENTIAL IMPACTS THROUGH ADDITIONAL 

REGULATORY FLEXIBILITY

 If adopted by the Board, the proposed limits will be incorporated in section 94509 

of the Consumer Products Regulation (title 17, California Code of Regulations, 

sections 94507-94517). To complement the mandatory VOC limits specified in section 

94509, the existing consumer products program provides a very high degree of 

compliance flexibility, through two voluntary, market-based programs: the IPP and the 

ACP Regulation. These options could be evaluated to minimize cost impacts. The IPP 

(section 94511) allows qualified manufacturers to sell products that have VOC contents 

greater than the applicable VOC limit, provided they demonstrate that such products 

actually emit less VOCs than representative products that comply with the VOC limit. 

Using the emissions averaging approach, the ACP is a voluntary regulation 

(title 17, CCR, sections 94540-94555) designed to allow multi-product VOC averaging 

as an alternative means of complying with the VOC limits. 

 Various manufacturers have formulated technologically-advanced IPP products 

that are more concentrated, higher in efficacy, or have some other chemical or physical 

properties that permit users to release less VOCs when using such products. To date, 

14 manufacturers have submitted and obtained approval for 25 IPP applications 

involving 23 products. Based on their participation in the program, it is reasonable to 

conclude that manufacturers are using this program to provide consumers with products 

that meet their needs, while lowering costs, improving the “market value” of their 

products, or otherwise maintaining profit margins. 

 The potential benefits of emissions averaging or “bubbling” for consumer product 

manufacturers under the ACP regulation have been documented by ARB staff (ARB, 

1994). In general, emissions averaging under approved ACPs allows manufacturers to 

choose the least-cost or other advantageous reformulation options for its product lines. 

Rather than directly complying with each and every VOC limit, manufacturers can 

choose to “overcomply” with some reformulations in order to offset the 

“undercompliance” of other product lines. The ACP regulation requires the net resulting 

emissions from products under such averaging plans to be no greater than the level 

which would have resulted had all the products under the ACP bubble directly complied 

with the applicable limits. In short, the same emission reductions are achieved while 

providing a high degree of formulation and marketing flexibility to manufacturers. To 

date, three manufacturers have implemented approved ACP averaging programs, 

reducing VOC emissions by about 4.9 million pounds more than would have occurred 
Technical Support Document Chapter VII - 176 

under the mandatory VOC limits. We expect that such emissions averaging will also 

benefit manufacturers subject to the proposed limits. 

 Overall, most affected businesses will benefit from the IPP and the ACP 

Regulation. Both programs are completely voluntary and impose no additional costs to 

businesses to meet their requirements other than testing and reporting requirements. 

Manufacturers who take advantage of these market-based programs presumably do so 

because it costs less than direct compliance with the limits or it provides some other 

market benefits. It should be noted that because the IPP and ACP provisions apply to 

VOC only, manufacturers of Pressurized Gas Dusters would not have the opportunity to 

use the provisions to address GWP limits. 

 According to previous staff analyses, the potential cost differential which might 

result from competition under the ACP between small and large firms would not 

necessarily cause extreme hardship on small firms. However, inclusion of the proposed 

limits in the ACP regulation may increase the level of competition for some products and 

may lead to the elimination of some marginal producers for those products. Such 

competition may also have minor impacts on California employment and payroll. 

However, the impact is expected to be positive in the long term. Any potential impacts 

on the ability of California businesses to compete with businesses in other states are 

also expected to be minimal. 

REFERENCES 

1. Air Resources Board. Technical Support Document for Proposed Amendments to 

the Suggested Control Measure for Architectural Coatings. 

 September, 2007. (ARB, 2007i) 

2. Air Resources Board. Proposed Amendments to the California Consumer 

Products Regulation and the Aerosol Coatings Regulation. 

 September 29, 2006. (ARB, 2006a) 

3. Air Resources Board. Initial Statement of Reasons for the Proposed 

Amendments to the California Aerosol Coating Products, Antiperspirants and 

Deodorants, and Consumer Products Regulations, Test Method 310, and 

Airborne Toxic Control Measure for para-Dichlorobenzene Solid Air Fresherners 

and Toilet/Urinal Care Products. May 7, 2004. (ARB, 2004b) 

4. Air Resources Board. Initial Statement of Reasons for the Proposed 

Amendments to the California Consumer Products Regulation Relating to 

Aerosol Adhesives. April 7, 2000. (ARB, 2000c) 
Technical Support Document Chapter VII - 177 

5. Air Resources Board. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation: Midterm Measures II. 

 September 10, 1999. (ARB, 1999) 

6. Air Resources Board. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation: Midterm Measures I. 

 June 6, 1997. (ARB, 1997b) 

7. Air Resources Board. Initial Statement of Reasons for Proposed Amendments 

Pertaining to Hairspray in the California Consumer Products Regulation. 

 February 7, 1997. (ARB, 1997c) 

8 Air Resources Board. Initial Statement of Reasons for a Proposed Statewide

Regulation to Reduce Volatile Organic Compound Emissions from Aerosol

Coating Products and Amendments to the Alternative Control Plan for Consumer

Products. February 3, 1995. Volume II. pp. VIII.1-VIII.20, X.1-X.13, and 

Appendix G. (ARB, 1995) 

9. Air Resources Board. Proposed Alternative Control Plan for Consumer Products. 

August, 1994. (ARB, 1994) 

10. Air Resources Board. Proposed Amendments to the Statewide Regulation to 

Reduce Volatile Organic Compound Emissions from Consumer Products - Phase 

II-Technical Support Document. October, 1991. (ARB, 1991a) 

11. Air Resources Board. Proposed Regulation to Reduce Volatile Organic 

Compound Emissions from Consumer Products – Technical Support Document. 

 August, 1990. (ARB, 1990c) 

12. Air Resources Board. Technical Review Group’s Proposed Architectural 

Coatings Suggested Control Measure – Staff Report. April 20, 1989. 

 (ARB, 1989c) 

13. California Department of Finance. Report: State Adds Almost 470,000 in 2006: 

2007 Population Nears 37.7 Million. May 1, 2007. (CA DOF, 2007) 

14. California Prison Industry Authority. On-Line Catalog. 2008. 

 http://catalog.pia.ca.gov/store.php?t=1210100718. (PIA, 2008) 

15. Chemical Engineering magazine. Chemical Engineering Plant Cost Index. 

 April, 2008. (Chemical Engineering, 2008) 

16. Chemical Engineering magazine. Chemical Engineering Plant Cost Index. 

 April, 1997. (Chemical Engineering, 1997) 
Technical Support Document Chapter VII - 178 

17. Dun and Bradstreet. Industry Norms and Key Business Ratios. Manufacturing - 

Volume 1. SIC # 2000-2999. 2006-2007. (D&B, 2006-2007) 

18. ICIS. ICIS Chemical Business. http://icispricing.com. April 11, 2008. (ICIS, 2008) 

19. United States Census Bureau. 2005 County Business Patterns (NAICS). 

California, 31 – Manufacturing. http://censtats.census.gov/cgi-bin/cbpnaic/cbpdetl.pl. 

April 22, 2008. (U.S. Census, 2005) 

Technical Support Document Chapter VIII -179

VIII. ENVIRONMENTAL IMPACTS

 In this rulemaking, ARB staff is proposing amendments to the Consumer 

Products Regulation that are designed to reduce volatile organic compounds (VOC) and 

air toxic emissions. The amendments would also reduce the use of greenhouse gas 

(GHG) compounds with high global warming potential (GWP) used in consumer 

products. 

 We have evaluated the environmental impacts of the proposed amendments on 

atmospheric processes and other media. Overall, we found that the proposed 

amendments would have beneficial effects and reduce exposure to ground-level ozone 

and air toxics. No significant adverse impacts were identified. However, several 

measures are proposed to mitigate the potential for adverse impacts to occur. In 

making these determinations, we evaluated how the proposed amendments would 

impact ground-level ozone concentrations, particulate matter (particularly secondary 

organic aerosols), climate change, stratospheric ozone depletion, air toxic emission 

exposure, water quality, solid waste, and energy use. 

Staff has conducted a qualitative health risk assessment that concludes that 

because VOCs are ozone precursors, public health is further protected by reducing 

VOC emissions. Staff has also determined that ambient air and personal exposures to 

perchloroethylene (Perc), methylene chloride (MeCl), and trichloroethylene (TCE) will 

be reduced by prohibiting the use of these chlorinated toxic air contaminants (TAC). 

Our analysis of the reasonably foreseeable environmental impacts of the 

methods of compliance is presented in subsections C through H below. Regarding 

reasonably foreseeable mitigation measures, the California Environmental Quality Act 

(CEQA) requires an agency to identify and adopt feasible mitigation measures that 

would minimize any significant adverse environmental impacts described in the 

environmental analysis. 

A. LEGAL REQUIREMENTS APPLICABLE TO THE ANALYSIS 

 

The CEQA and ARB policy require an analysis to determine the potential 

adverse environmental impacts of proposed regulations. Because ARB’s program 

involving the adoption of regulations has been certified by the Secretary of Resources 

(see Public Resources Code section 21080.5), the CEQA environmental analysis 

requirements are allowed to be included in ARB’s Initial Statement of Reasons instead 

of preparing an environmental impact report or negative declaration. In addition, ARB 

will respond in writing to all significant environmental points raised by the public during 

the public review period or at the Board hearing. These responses will be contained in 

the Final Statement of Reasons for the proposed amendments to the Consumer 

Products Regulation. 
Technical Support Document Chapter VIII -180

Public Resources Code section 21159 requires that the environmental impact 

analysis conducted by ARB include the following: (1) an analysis of the reasonably 

foreseeable environmental impacts of the methods of compliance; (2) an analysis of 

reasonably foreseeable feasible mitigation measures; and, (3) an analysis of reasonably 

foreseeable alternative means of compliance with the regulation. Before we present our 

analysis of the environmental impacts, for ease of the reader the proposed amendments 

are summarized in Part B. 

B. SUMMARY OF PROPOSED AMENDMENTS 

1. Proposed VOC Standards 

Staff is proposing to establish new or lower VOC limits for multiple categories. 

These limits would reduce VOC emissions by about 5.8 tons per day when fully 

effective. The proposed amendments to reduce VOC emissions would partially fulfill the 

consumer product reduction commitment contained in the 2007 Strategy to meet the 

federal ozone standard. 

 

2. Proposed Greenhouse Gas Measure 

We are proposing an amendment to reduce the use of GHG with high GWP in 

Pressurized Gas Duster products. Pressurized Gas Duster products would not be 

allowed to contain a compound that has a GWP of 150 or greater. This proposal would 

essentially eliminate use of hydrofluorocarbon (HFC) 134a in this category. In 2010, we 

anticipate that this measure would achieve a reduction equivalent to reducing of 

0.20 million metric tons of carbon dioxide (CO2) per year. 

To ensure that the VOC content of these products does not increase as a result 

of reformulation to meet the GWP limit, a 1 percent by weight, including fragrance, VOC 

limit is also being proposed for Pressurized Gas Duster products. To mitigate potential 

exposure to air toxics, we are also proposing to prohibit use of MeCl and Perc in this 

category. 

3. Proposed VOC Exemption 

Staff is proposing that the definition of VOC be modified to exclude two isomers 

of hydrofluoroether (HFE) 7200. In a report titled “Environmental Impact Assessment of 

Selected Halogenated Chemicals,” (ARB, 2008b) ARB staff determined that use of 

HFE-7200 has negligible impacts on ground-level ozone formation. Staff believes that 

exemption of this negligibly reactive compound would provide additional reformulation 

flexibility. 
Technical Support Document Chapter VIII -181

4. Proposed Toxics Prohibition 

Staff is also proposing a measure to reduce emissions of three TACs in the 

categories proposed for VOC regulation where they are, or could potentially, be used. 

The proposed prohibition on the use of Perc, MeCl, and TCE in six categories would 

result in a reduction of about 0.20 tons per day when fully effective. 

5. Proposed Definitions and Clarifying Language 

 Staff is also proposing additional language modifications. These modifications 

include clarifying language for the product date coding requirement, requirements for 

dilutable products sold in pump spray containers, toxic compound prohibitions, and 

additional requirements for categories such as Fabric Softener – Single Use Dryer 

Product, Personal Fragrance Product with 20 percent or less fragrance, and Sealant or 

Caulking Compound. Other proposals include the correction of a drafting error in the 

Table of Standards regarding Furniture Maintenance Product. The long-standing 

exemption for solid/paste wax forms would be reinstated. 

C. SUMMARY OF IMPACTS ON ATMOSPHERIC PROCESSES 

In this section, we evaluate the impacts on atmospheric processes. The 

evaluation includes our assessment on whether the proposed amendments would have 

a positive, negative, or no impact on these atmospheric processes. 

1. Impacts of Proposed Amendments on Ground-level Ozone 

Concentrations 

Enhanced ground-level ozone formation involves the interaction between VOCs 

and oxides of nitrogen (NOx) in the presence of sunlight. The rate of ozone generation 

is related closely to both the amount and reactivity of VOC emissions as well as the 

amount of NOx emissions available in the atmosphere (Seinfeld and Pandis,1998). 

Ozone is a colorless gas and the chief component of urban smog. It is one of the 

State’s more persistent air quality problems. Ninety-three percent of Californians, or 

36 million people, live in areas designated as non-attainment for the federal 8-hour 

ozone standard. It has been well documented that ozone adversely affects respiratory 

function of humans and animals. Research has shown that, when inhaled, ozone can 

cause respiratory problems, aggravate asthma, impair the immune system, and cause 

increased risk of premature death. 

Not only does ozone adversely affect human and animal health, but it also affects 

vegetation throughout most of California resulting in reduced yield and quality in 

agricultural crops, disfiguration or unsatisfactory growth in ornamental vegetation, and 

damage to native plants. More information on the impacts of exposure to ozone can be 

found in Chapter IV, of this Technical Support Document. 

 
Technical Support Document Chapter VIII -182

a. Proposed VOC Standards

The proposed amendments are designed to reduce VOC emissions by about 

5.8 tons per day when fully effective. Reducing these ozone precursor emissions will 

result in a positive environmental impact by lowering the concentrations of ground-level 

ozone in the atmosphere. If we assume that the average ozone forming potential of 

consumer product VOC emissions is about 1.50 pounds of ozone per pound of VOC 

emitted (based on the maximum incremental reactivity (MIR) scale, see title 17, CCR, 

sections 94700-94701), then we would predict the resulting ozone reductions would be 

about 9 tons per day. The categories proposed for regulation and the corresponding 

VOC emission reductions are shown in Table VIII-1. 

b. Proposed Greenhouse Gas Measure

The proposed GHG measure would have no impact on ground-level ozone 

concentrations. This is because the proposal essentially requires replacing HFC-134a 

with HFC-152a. Both HFC-134a and HFC-152a are excluded from the definition of 

VOC due to negligible photochemical reactivity with respect to ozone. However, to 

ensure VOC emissions do not increase, as a mitigation measure, staff is proposing to 

set a 1 percent by weight VOC limit to prevent VOC increases as products reformulate. 

c. Proposed VOC Exemption 

The exemption of HFE-7200 will likely have a positive impact on ground-level 

ozone concentrations. Whenever this negligibly reactive compound replaces more 

reactive VOCs the result will be a reduction in ground-level ozone concentrations. 

Replacing HFE-7200 for similarly unreactive compounds, such as MeCl, Perc, and 

hydrochlorofluorocarbon (HCFC) 141b, should have no impact on ground-level ozone 

concentrations. 

d. Proposed Toxics Prohibition

In accordance with CEQA, we are proposing a mitigation measure to ensure that 

emissions of Perc, MeCl, and TCE do not increase when products are reformulated. As 

such, we are proposing to prohibit the use of these TACs in Carpet/Upholstery 

Cleaners; Fabric Protectants; Multi-Purpose Lubricants; Penetrants; Sealant or Caulking 

Compounds; and Spot Removers. The prohibition of these three solvents is necessary, 

particularly for MeCl and Perc because they are also exempt VOCs. However, this 

proposal to prohibit the use of Perc, MeCl, and TCE in these six categories could result 

in a slight increase in VOC emissions. Products containing these TACs may have to 

reformulate using VOC solvents. Staff, therefore, evaluated the potential for VOC 

emission increases resulting from this proposal. 
Technical Support Document Chapter VIII -183

Table VIII-1 

Proposed VOC Limits, Emissions, and Reductions at Effective Date 

Product Category 

Product 

Form 

Proposed 

VOC Limit 

(percent by 

weight)

2008 VOC 

Emissions* 

(tons per day)

Reductions 

at Effective 

Date 

(tons per day)

Astringent/Toner 

(non-FDA regulated) a All 35 0.62 0.11 

Aerosol 5 0.32 0.07 

Carpet/Upholstery Cleanera

Nonaerosol 1 0.29 0.07 

Aerosol 17 0.27 0.08 

Dusting Aida

Nonaerosol 3 0.01 0.00 

Fabric Protectanta Nonaerosol 1 0.18 0.08 

Fabric Softener – 

 Single Use Dryer Producta All 0.05 grams per use** 0.52 0.21 

Floor Maintenance Producta All 1 0.11 0.07 

Floor Polish or Wax – 

 Wood Floor Waxa All 70 0.06 0.01 

Glass Cleanerb Aerosol 10 0.33 0.03 

Motor Vehicle Washa All 0.2 0.38 0.14 

25c

Multi-purpose Lubricant – 4.08 2.04 

 excluding solid & semisolidc/e All 

10e 1.27 

Aerosol 25 *** 0.00 

Odor Remover/Eliminatora

Nonaerosol 6 0.12 0.03 

Penetrantc All 25 0.40 0.15 

Personal Fragrance Product 

(products with 20% or less 

fragrance) d

All 75+

 10.89 0.41 

Pressurized Gas Dustera All 1 0 0 

Chemically Curingb Nonaerosol Sealant or 3 1.9 0.22 

Caulking 

Compound Non-Chemically 

Curinga

Nonaerosol 1.5 0.68 0.12 

Aerosol 15 0.76 0.24 

Spot Removera

Nonaerosol 3 0.29 0.05 

Aerosol 8 0.01 0.00 

Tire or Wheel Cleanera

Nonaerosol 2 0.14 0.06 

Windshield Water Repellenta All 75 0.23 0.04 

Total Emissions 2008 22.61 tons per day

Total Reductions 2015 5.76 tons per day 

 * Survey emissions adjusted for market coverage, Effective Dates: 

 and grown to the 2008 calendar year a: 12/31/2010 

 ** Grams per use limit provides emissions reductions equivalent b: 12/31/2012 

 to 2.6% VOC limit, including fragrance c: 12/31/2013 

 *** Omitted to protect confidentiality d: 12/31/2014 

 + Remove “Grandfather” clauses e: 12/31/2015
Technical Support Document Chapter VIII -184

The emissions of chlorinated solvents in these categories is about 0.20 tons per 

day. If we assume that these solvents are replaced one-to-one with VOC solvents, then 

the increase in VOC emissions would be no more than 0.20 tons per day. We expect 

VOC increases will be less because other reformulation options are available. Note, 

however, that TCE is a VOC. This is a neutral impact because VOC would replace 

VOC. Although no aerosol or non-aerosol Fabric Protectant products currently contain 

any of these chlorinated solvents, this category is included in the proposed prohibition to 

prevent use in reformulations. The 5.8 tons per day VOC reduction already accounts 

for the increase of VOC emissions due to the toxics prohibition proposal. Staff believes 

the potential slight increase in VOC emissions is out-weighed by the benefit of reducing 

exposure to these probable human carcinogens. 

e. Proposed Definitions and Clarifying Language 

We expect no impact or a slight benefit on ground-level ozone concentrations 

resulting from the proposed changes to definitions and language change proposals. 

Currently, the Consumer Products Regulation states that any product that is designed to 

be diluted prior to use is subject to the VOC limits after the product has been diluted. 

Staff has become aware of products packaged in pump spray containers that appear to 

be marketed as “ready-to-use” products, but are designed to be diluted by the consumer 

prior to use. Staff believes this approach to packaging may be diminishing VOC 

reductions, and is a potential circumvention of the intent of the regulation. 

Therefore, the proposal to apply the VOC limit for dilutable products sold in pump 

spray containers, prior to the minimum recommended dilution, could provide a slight 

benefit. It is likely these products are used undiluted, resulting in higher VOC emissions 

than allowed by the VOC limit. The other language changes add clarity and do not 

impact emissions. 

 

2. Impacts of Proposed Amendments on Particulate Matter (Secondary 

Organic Aerosols) 

Fine particulate matter (PM) is prevalent in the urban atmosphere (see, for 

example, Pandis et al., 1992), and ambient PM, especially those with diameters less 

than two and a half micrometers (PM2.5), is known to have negative impacts on human 

health (Schwartz et al.,1996; Moolgavkar and Luebeck, 1996). Like ozone, PM can be 

formed via atmospheric oxidation of organic compounds (Finlayson-Pitts and 

Pitts, 2000). Significant advances have been made in the theoretical and the 

experimental studies of the formation of secondary organic aerosols (SOA) 

(Pankow, 1994a, Pankow, 1994b; Odum et al., 1996; Seinfeld and Pandis,1998; Harner 

and Bidleman, 1998; Kleindienst, et al., 1999; Yu et al., 1999). In addition, modeling 

techniques to determine the amount of ozone as well as the amount of aerosol formed 

from a VOC have been established (Bowman et al., 1994), and the concept similar to 

maximum incremental reactivity is being applied to quantitatively assess the aerosol 

formation potential of a VOC (i.e. incremental aerosol reactivity) (Griffin et al., 1999). 
Technical Support Document Chapter VIII -185

Based on the results of these studies, we now know that there is a mechanistic 

linkage between ozone formation and SOA formation of a VOC. Because of this 

relationship, the proposed amendments may also affect the SOA formation potential of 

consumer products. The analysis of the impact on SOA formation resulting from 

implementing the proposed VOC limits is detailed below. 

Although most organic compounds contribute to ozone formation, SOA is usually 

formed from photooxidation of organic compounds with carbon numbers equal to six or 

more (Seinfeld and Pandis, 1998). It has also been shown that aromatic compounds 

are more likely to participate in the formation of SOA than are alkanes (Grosjean, 1992; 

Pandis et al., 1992). In other words, only chemicals that react fast enough in the 

atmosphere will generate sufficient amounts of low volatility products for forming 

aerosols. In general terms, the potential to form SOA among commonly used classes of 

VOCs used in consumer products could be described by the following order, with the 

lower molecular weight alkanes and ketones being least likely: 

Least Likely Lower molecular weight alkanes and ketones (6 carbons or 

less) 

Higher molecular weight alkanes 

Higher molecular weight aromatics (polysubstituted benzenes) 

More Likely Lower molecular weight aromatics (C6 - C8 compounds) 

a. Proposed VOC Standards

The analysis of the potential impact on PM formation from the proposed VOC 

limits assumes that to meet the proposed limits will require replacing 5.8 tons per day of 

VOCs for 5.8 tons per day of non-VOC ingredients or exempt VOCs. To meet the 

proposed VOC limits, manufacturers generally have five reformulation options: use of 

exempt VOCs, such as acetone or methyl acetate; use of LVP-VOC solvents; use of 

water; increasing ‘solids’ content; or use of non-VOC propellants. Substitution for VOCs 

with water, higher solids content, or non-VOC propellants would likely result in a small 

reduction in SOA formation. The most likely exempt VOC solvents to be used to 

comply, acetone and methyl acetate, both having three carbon atoms, have little 

potential to contribute to SOA formation. Indeed, it has been predicted that there would 

be no SOA yield from acetone (Pandis et al., 1992). Hence, use of these compounds 

could also result in a reduction in SOA. 

To the extent manufacturers may reduce overall VOC content but formulate with 

stronger solvents could result in increased SOA formation. This is because the 

commonly used stronger solvents are aromatic compounds, such as xylenes and 

toluene, which are known to have higher SOA potentials than other commonly used 

VOCs. On the other hand, if product reformulation involves the substitution of an 

aromatic by a non-aromatic species, the SOA formation potential of the product is likely 

to be reduced. If VOC aromatics are replaced with LVP-VOC aromatic compounds, a 

decrease in SOA potential should also occur. However, substitution of LVP-VOC 
Technical Support Document Chapter VIII -186

alkane or aromatic compounds for smaller low molecular weight alkanes could result in 

a slight SOA increase (Grosjean, 1992). 

Because we can not predict how manufacturers will choose to reformulate, we 

can not fully evaluate the potential for increased SOA formation. However, it is likely to 

be only a slight potential for increase, if any, due to the variety of reformulation options 

available. At any rate, it will not be a significant adverse impact. Additionally, any 

reformulations that result in increased SOA would likely be offset by reformulations 

resulting in lower SOA. We will continue to monitor implementation of the regulation 

and reassess the impacts as more data become available. 

b. Proposed Greenhouse Gas Measure

 Because this proposal essentially requires the replacement of one compound for 

another – each with two carbon atoms – we expect the proposal to have no impact on 

PM2.5 concentrations or SOA. 

c. Proposed VOC Exemption

 As mentioned above, SOA is generally formed from oxidation of compounds with 

six or more carbon atoms. We do not expect HFE-7200 to increase SOA 

concentrations because HFE-7200 is comprised of two isomers, each with four carbon 

atoms. 

d. Proposed Toxics Prohibition 

The proposal to prohibit TACs in six categories should have no or negligible 

impacts on SOA formation because replacements for these TACs (alkanes or exempt 

compounds) are not known to have strong SOA formation potentials. Prohibiting use of 

Perc and MeCl in Pressurized Gas Duster products also should have no impact. 

e. Proposed Definitions and Clarifying Language

 Because proposed language changes and definitions generally only clarify or 

provide descriptions, we expect no impact on PM2.5 or SOA. 

3. Impacts of Proposed Amendments on Climate Change 

Climate change, or global warming is the process whereby emissions of 

anthropogenic pollutants, together with other naturally-occurring gases, absorb infrared 

radiation in the atmosphere, leading to increases in the overall average global 

temperature. While CO2 is the largest contributor to radiative forcing, methane, 

halocarbon, N2O, and other species also contribute to climate change. 

Gases in the atmosphere can contribute to the greenhouse effect both directly 

and indirectly. Direct effects occur when the gas itself is a GHG. While there is relative 
Technical Support Document Chapter VIII -187

agreement on how to account for these direct effects of GHG emissions, accounting for 

indirect effects is more problematic. Indirect radiative forcing occurs when chemical 

transformations of the original gas produce other GHGs, when a gas influences the 

atmospheric lifetimes of CH4, and/or when a gas affects atmospheric processes that 

alter the radiative balance of the earth (e.g., affect cloud formation). 

As mentioned earlier, the GWP of a compound may reflect a direct effect as well 

as an indirect effect on global warming. The direct effect is the warming due to the 

absorption of radiation by molecules of the compound in question. VOCs, CO2, HFCs, 

HFEs, and HCFCs all have direct effects. The indirect effect is due to the impact that 

the presence of the compound has on the concentration of other GHGs. For example, 

VOCs contribute indirectly to global warming, in-so-far as they react chemically in the 

atmosphere in ways that increase GHG concentrations, most notably, concentrations of 

ozone and methane. The indirect forcing of VOCs is, however, still poorly quantified 

and requires the use of global three-dimensional chemical transport models. 

Even though VOCs have direct effects, they are considered as GHGs because of 

their role in creating ozone and in prolonging the life of methane in the atmosphere, 

although the effect varies depending on local air quality. A further narrative on climate 

change and expected impacts is included in Chapter IV of this Technical Support 

Document. 

 

a. Proposed VOC Standards

 As just described, VOCs are considered GHGs because of their role in creation 

of ozone. However, because the VOC limits will reduce the total amount of VOCs, and 

thereby ground-level ozone concentrations, the proposed VOC limits should reduce 

consumer product’s impacts on climate change. While we expect an overall positive 

impact, two reformulation options may lead to very slight increases in GHG emissions. 

These are discussed below. 

To meet the proposed VOC limits to a limited extent, CO2 may replace 

hydrocarbon propellants in some products. The 2003 Survey data indicate that CO2 is 

already used in certain consumer products considered for regulation, including MultiPurpose Lubricants, and Penetrants. In these categories, CO2 use is likely to increase 

as manufacturers reformulate to meet the lower proposed VOC limits. In other 

categories with aerosol product forms, CO2 may also be a reformulation pathway. Even 

though CO2 has a direct effect on climate change, co-benefits are expected to the extent 

that CO2 replaces VOC propellants in consumer products. Specifically, less ozone and 

methane will be formed, thus lowering the population’s exposure to a pollutant with 

serious health effects. Further, the contribution of CO2 to global warming is likely less 

than that of the VOC being replaced. In addition, most CO2 used as a propellant is a 

recycled by-product of existing processes and, therefore, does not increase global 

warming from a lifecycle standpoint (ARB, 1999). 

 
Technical Support Document Chapter VIII -188

 Another reformulation path for some aerosol product manufacturers may be to 

replace some or all the typical hydrocarbon propellants with HFC-152a or HFC-134a. 

These compounds are exempt VOCs. We do not predict increased usage of HFC-134a 

due to its higher GWP, and because its use is not recommended except in certain 

specific uses. In consumer products, HFC-134a is generally used when flammability is 

a concern. 

 Staff believes that for the Spot Remover category under consideration for 

regulation, HFC-152a may be a potential reformulation option. If all VOC propellants in 

these categories were replaced with HFC-152a, total emissions of HFC-152a would be 

0.17 tons per day. This represents a worst-case scenario. Staff believes usage would 

be considerably less because of raw material cost and because other reformulation 

options are available. 

Also, when cost considerations are factored in (HFC-152a is about $1.80 per 

pound, HFC-134a is $3.50 versus VOC propellants at $1.00 per pound), it is anticipated 

that manufacturers will use as little HFC-152a as possible, or none at all, when 

reformulating their aerosol products. ARB staff does not expect the price of HFCs to 

change appreciably in the near future, thus a significant increase in use is not 

anticipated. 

Based on the foregoing, while there is a slight potential for a very small increase 

in the emissions of HFC-152a, the proposed VOC limits will likely more than offset this 

impact by reducing concentrations of ground-level ozone. 

b. Proposed Greenhouse Gas Measure

The proposal to reduce the use of compounds with high GWP in Pressurized 

Gas Dusters will have an overall beneficial impact on climate change. As proposed, the 

GWP limit for Pressurized Gas Dusters would require products using HFC-134a to 

reformulate with HFC-152a. This reformulation would be equivalent to reducing 

0.20 MMT CO2 per year, effective December 31, 2010. 

c. Proposed VOC Exemption

HFE-7200 is a solvent proposed for exemption from the VOC definition based on 

its photochemical reactivity. It has a relatively low GWP of 59 based on the FAR 

values. Its main use is in precision cleaning, and its use will likely be limited to 

applications where HCFC-141b is, or has been, used. Because it is a stratospheric 

ozone depleting compound, HCFC-141b production is no longer allowed. However, use 

of existing stockpiles is allowed. In addition to depleting stratospheric ozone 

concentrations, HCFC-141b is also a fairly potent global warming compound with a FAR 

GWP value of 725. HFE-7200 is purported as an all or partial replacement for 

HCFC-141b in that it provides mild cleaning ability and reduces flammability. In the 

short-term, to the extent HFE-7200 is used to replace HCFC-141b, a reduction in the 

potency of GHG emissions is expected. This is a direct emission benefit related to 
Technical Support Document Chapter VIII -189

climate change. To the extent HFE-7200 replaces VOCs in various consumer product 

categories, there will be a small increase in direct GHG emissions. This will likely be 

offset by the indirect benefit of reduced ground-level ozone concentrations. 

A longer term potential benefit may also be expected. Precision cleaning 

products where flammability is a concern generally rely on use of the propellant 

HFC-134a, a potent global warming gas. Because of the ability to reduce flammability, 

as well as its solubility with CO2, in the future, it is possible that use of HFE-7200 in 

combination with CO2 as a propellant, could lead to further limiting the use of HFC-134a 

(Werner, 2008). 

d. Proposed Toxics Prohibition

The prohibition on the use of Perc, MeCl, and TCE will likely have a negligible to 

positive impact on GHG emissions. If VOCs are used to replace these TACs, because 

VOCs play a role in both direct and indirect impacts on global warming, this would lead 

to a very slight increase in global warming emissions. We believe the reduced 

exposure to these TACs out-weighs this potential increase. 

e. Proposed Definitions and Clarifying Language

 Clarifying language and proposed definition changes should have no impact on 

global warming. 

 

4. Impacts of Proposed Amendments on Stratospheric Ozone Depletion

The stratospheric ozone layer shields the earth from harmful ultraviolet (UV) 

radiation. Depletion of the earth’s ozone layer allows a higher penetration of UV 

radiation to the earth's surface. This increase in UV radiation penetration leads to a 

greater incidence of skin cancer, cataracts, and impaired immune systems. Reduced 

crop yields and diminished ocean productivity are also expected. Because the chemical 

reactions which form ground-level ozone are driven by UV radiation, it is conceivable 

that a reduction in stratospheric ozone may also result in an increase in the formation of 

photochemical smog because of the increased levels of UV radiation on the earth’s 

surface (ARB, 2000b). The chemicals most implicated as causing stratospheric ozone 

depletion are chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs), and 

halons (U.S. EPA, 2003). Specifically, the chlorine or bromine atoms released by 

photolysis of the compounds react in chain reactions leading to the catalytic destruction 

of ozone (Finlayson-Pitts and Pitts, 2000). 

Solar irradiation in the stratosphere contains sufficient UV light to break down 

CFCs and HCFCs to yield chlorine atoms that convert ozone to molecular oxygen. 

However, this UV light is not strong enough to break down HFCs and HFEs to create 

fluorine atoms. In addition, the molecular structure of HFCs and HFEs includes 

hydrogen atoms, which renders them susceptible to attack by hydroxyl radicals in the 
Technical Support Document Chapter VIII -190

troposphere. Therefore, these chemicals have a relatively short atmospheric lifetime 

which does not allow any appreciable amounts to penetrate into the stratosphere 

(ARB, 2008b). 

To address stratospheric ozone depletion, the Montreal protocol was enacted in 

1989, to phase out a number of CFCs, HCFCs, and halons. As a signatory of this 

protocol, the United States, in the Federal Clean Air Act of 1990 established timetables 

for ceasing production (see part 40, Code of Federal Regulations, section 602). In 

general, the protocol establishes dates by which certain compounds can no longer be 

manufactured; however, existing stocks can continue to be used in some applications 

until exhausted. 

a. Proposed VOC Standards

Reducing VOCs will have no impact on stratospheric ozone depletion. As 

products reformulate to meet the proposed VOC limits, provisions in the Consumer 

Products Regulation (see section 94509(e)) already prohibit the use of various 

stratospheric ozone depleting compounds. This provision ensures there will be no 

increased use of stratospheric ozone depleting compounds. 

b. Proposed Greenhouse Gas Measure

The proposed GHG measure will have no impact on stratospheric ozone 

depletion. Neither HFC-134a nor HFC-152a contribute to stratospheric ozone 

depletion. This is mainly because these compounds do not contain chlorine. Therefore, 

substituting HFC-152a for HFC-134a in Pressurized Gas Dusters has no impact. 

Additionally, these compounds have relatively short atmospheric lifetimes. Both 

compounds contain hydrogen which makes them susceptible to hydroxyl radical attack 

in the troposphere. 

 

c. Proposed VOC Exemption

Use of HFE-7200 would be a positive impact if it replaces HCFC-141b, a known 

stratospheric ozone depleting compound. HFE-7200 itself is not an ozone depleting 

compound because it does not contain chlorine. In addition, because the compound 

contains hydrogen it may be susceptible to hydroxyl radical attack in the troposphere. 

 

d. Proposed Toxics Prohibition

 

 The proposed prohibition on the use of Perc, MeCl, and TCE will likely have a 

negligible impact on stratospheric ozone depletion. In order to comply with this 

prohibition, VOCs may replace these TACs in reformulated products. If this occurs, 

VOCs are not stratospheric ozone depleting compounds. Additionally, manufacturers 

are precluded from reformulating with stratospheric ozone depleting compounds 

because provisions in the regulation already prohibit use of various stratospheric ozone 

depleting compounds (94509(e)). 
Technical Support Document Chapter VIII -191

e. Proposed Definitions and Clarifying Language

 Clarifying language and proposed definition changes will have no impact on 

stratospheric ozone depletion. 

D. OTHER POTENTIAL ENVIRONMENTAL IMPACTS

1. Impacts of Proposed Amendments on Solid Waste Disposal 

Consumer products contribute to the solid waste stream by virtue of the 

containers and the towelettes or “wipes” used to deliver the product. Therefore, we 

evaluated the potential impacts of the proposed amendments on the solid waste stream. 

a. Proposed VOC Standards

We do not expect an adverse impact on solid waste disposal from the proposed 

amendments relating to VOC limits. This is because we do not anticipate any changes 

in packaging or disposal due to the amendments. We also designed the VOC limit for 

Fabric Softener – Single Use Dryer Product so that the waste stream will not be 

adversely impacted by increasing sheet size to comply. To mitigate the potential for 

solid waste impacts from this category, staff is proposing a VOC standard based on 

grams of VOC per use (typically a single dryer sheet per load), as opposed to a percent 

by weight VOC limit. 

It has been suggested that end-use consumers of Fabric Softeners – Single Use 

Dryer Products may begin using more than a single dryer sheet per load of laundry. 

The contention is that the reformulated dryer sheet products will be perceived to be 

inadequate, because of the reductions in fragrance. No data were provided to support 

this claim. Moreover, this suggestion implies that the consumer will essentially begin 

doubling the cost per load of clothes dried. This is highly unlikely. Absent data, staff 

has determined this potential increased use to be unfounded. It has also been 

suggested that the end-use consumers will switch use to liquid products which are 

packaged in bulkier plastic containers. Again, no data were provided to support this 

claim. However, we intend to monitor product sales trends through periodic surveys, as 

is always done, to ensure that unintended consequences of establishing the proposed 

VOC limit do not occur. 

 

b. Proposed Greenhouse Gas Measure

We expect that the GHG proposal could result in reducing the solid waste 

stream. This is because data show that Pressurized Gas Duster products that use 

HFC-152a typically get more uses per can than products that use HFC-134a (Dupont & 

Falcon, 2004). We also note that no significant changes in packaging will be needed to 

reformulate with HFC-152a. 
Technical Support Document Chapter VIII -192

c. Proposed VOC Exemption

The proposed VOC exemption should have no solid waste impacts because we 

expect HFE-7200 to replace VOCs on a one-to-one basis. No new or additional 

packaging should be needed. 

d. Proposed Toxics Prohibition

The proposed TAC prohibition should have no impact because the compounds 

used to replace Perc, MeCl, and TCE (VOCs or exempt compounds) require no 

different packaging, or additional packaging. 

e. Proposed Definitions and Clarifying Language

By specifying that VOC content be determined prior to the minimum dilution, for 

products intended for dilution, but sold in ready-to-use pump sprays should reduce the 

amount of solid waste. If products are used as is, without making the dilution, the 

number of uses per container would be greatly reduced, compared to if the product 

were properly diluted. The overall result, without this provision, would be that more 

containers would be landfilled. 

2. Impacts of Proposed Amendments on Water Quality 

Because of how consumer products are used there are potential water quality 

impacts. Therefore, we evaluated the impacts of the proposed amendments on water 

quality. 

a. Proposed VOC Standards

Reducing VOCs should have no impact on water quality and could ultimately 

result in a positive impact. As products reformulate to meet the proposed VOC limits, to 

a limited extent, water may replace VOCs in some products. This would have a positive 

impact on water quality by reducing the quantity of VOCs that might be introduced to the 

water supply. If exempt compounds replace VOCs in reformulated products, there 

should be no impact. This is because as far as water chemistry is concerned, VOCs 

and VOC exempt compounds are similar compounds. It is also true that many VOCs 

are biodegraded as they pass through the waste water stream. 

b. Proposed Greenhouse Gas Measure

 The proposal to reduce the use of compounds with high GWP in Pressurized 

Gas Duster products will have no impact on water quality. Both HFC-134a and 

HFC-152a have an air fate and are not likely to enter the water. 
Technical Support Document Chapter VIII -193

c. Proposed VOC Exemption

Use of HFE-7200 is expected to have no impact or a slightly beneficial impact on 

water quality. HFE-7200 is volatile, and based on its intended use, emissions have an 

air fate. However, there may be a slight benefit to sanitation districts resulting from the 

potential decrease in the amount of chlorinated solvents reaching water treatment 

facilities if HFE-7200 is used in place of Perc, MeCl, or TCE in products (ARB, 2008b). 

d. Proposed Toxics Prohibition

Current use of Perc, MeCl, and TCE in Carpet/Upholstery Cleaner; Fabric 

Protectant; Multi-Purpose Lubricant; Penetrant; Sealant or Caulking Compound; and 

Spot Remover is not expected to have an impact on water quality. This is because as 

used, these solvents have an air fate. However, the proposed prohibition of Perc, MeCl, 

and TCE from these six categories may prevent an increase in the amount of 

chlorinated solvents reaching storm drains, and waste water treatment plants if these 

products are misused or improperly discarded. As a result of this proposal, TAC 

emissions will be reduced by about 0.20 tons per day in 2010. 

e. Proposed Definitions and Clarifying Language 

Because the proposed language changes and definitions generally only clarify or 

provide descriptions, we expect no impacts on water quality. 

3. Impacts of Proposed Amendments on Energy 

 We do not expect the proposed amendments to result in an increase in energy 

use because production and shipment of the reformulated products will be similar to 

existing products. 

It has been suggested that end-use consumers of Fabric Softeners – Single Use 

Dryer Products may shift use to liquid products. The contention is that the reformulated 

dryer sheet products will be perceived to be inadequate, related to potential reductions 

in fragrance. If this were to occur, fuel usage could increase as products are 

transported, due to the weight differential between Fabric Softeners – Single Use Dryer 

Products and liquid products. No data were provided to support this claim. Absent 

data, we believe the concern with this potential switch is unfounded. Moreover, other 

data show that consumers favor the use of Fabric Softeners – Single Use Dryer 

Products (SDA, 2006a). However, we intend to monitor product sales trends through 

periodic surveys, as is always done, to ensure that unintended consequences of 

establishing the proposed VOC limit do not occur. 
Technical Support Document Chapter VIII -194

E. ANALYSIS OF REASONABLY FORESEEABLE MITIGATION MEASURES 

As part of our obligations under CEQA, the ARB staff is required to evaluate and 

mitigate potential adverse environmental impacts resulting from regulatory proposals. 

Also, pursuant to Health and Safety Code section 39650 et seq., the ARB is required to 

identify and control TACs. The Health and Safety Code defines a TAC as “...an air 

pollutant which may cause or contribute to an increase in mortality or serious illness, or 

which may pose a hazard to human health.” Moreover, in accordance with 

section 39666 of the Health and Safety Code, for TACs for which no safe exposure 

threshold has been established, the ARB is required to “.... reduce emissions to the 

lowest level achievable through application of best available control technology or a 

more effective control method....” 

Several chemicals currently used in the consumer product formulations 

considered for regulation have been identified as TACs. An increased or continued use 

of TACs in any of the consumer product categories considered for regulation could lead 

to a potential adverse environmental impact. ARB staff has evaluated this potential and 

has concluded that there would be a potential adverse environmental impact of 

implementing the VOC limits. Therefore, staff is proposing mitigation measures 

designed to ensure that use of TACs will be reduced or prohibited, resulting in a positive 

environmental impact. 

 We also found that the GHG measure could result in increased VOC emissions 

as products are reformulated to comply with the GWP limit. A mitigation measure is 

proposed to address this potential. 

 In evaluating proposed VOC reduction opportunities for Fabric Softener – Single 

Use Dryer Product we considered, as is typically done, a percent by weight VOC limit. 

However, we determined using this approach could result in simply increasing the sheet 

size to comply. Therefore, the gram of VOC per use limit is designed as a mitigation 

measure to address this potential impact on the solid waste stream. 

1. Proposed Mitigation Measure Related to Establishing VOC Limits 

 

Staff believes that specific mitigation measures are necessary to restrict the use 

of three chlorinated solvents, Perc, MeCl, and TCE because of their potential to cause 

cancer. Two of these TACs used in some consumer products, MeCl, and Perc, are 

specifically exempted from the VOC definition (section 94508 of the Regulation) in 

recognition of their very low ozone-forming capability. Thus, the potential exists that to 

meet VOC limits, manufacturers could reformulate using these exempt VOC TACs 

leading to an adverse impact. Trichloroethylene is regulated as a VOC, such that its 

use should not increase as products reformulate to meet VOC limits. However, 

because it is a probable human carcinogen, we are proposing a specific mitigation 

measure to address its use. Below, we provide some general information on toxicity, 

and the usage of Perc, MeCl, and TCE. Further information on these chemicals is 
Technical Support Document Chapter VIII -195

included in “The Proposed Amendments to the California Consumer Products 

Regulation and the Aerosol Coatings Regulation,” released September 29, 2006. 

 

Presented in Table VIII-2 are pollutant-specific health effects values developed 

for Perc, MeCl, and TCE to characterize the relationship between a person's exposure 

to these TACs and the incidence or occurrence of an adverse health effect. Unit risk 

factors (URF), cancer potency factors, and reference exposure levels (RELs) are 

shown in Table VIII-2. Also included in Table VIII-2 are the non-cancer acute and 

chronic toxicological endpoints for Perc, MeCl, and TCE. 

Table VIII-2 

Pollutant-Specific Health Effects Values Used for Determining 

Potential Health Impacts 1 

 1 Health effects values and toxicological endpoints were obtained from the following three sources: 

 (OEHHA, 2005a; OEHHA, 2005b; OEHHA, 2000) 

A URF is defined as the estimated upper-confidence limit (usually 95 percent) 

probability of a person contracting cancer as a result of constant exposure to a 

concentration of 1μg/m3

 over a 70-year lifetime. In other words, using the URF for Perc 

as an example, which is 5.9 x 10-6 (microgram per cubic meter)-1 or (μg/m3)

-1, the 

potential excess cancer risk for a person continuously exposed over a 70-year lifetime 

to 1μg/m3

 of Perc is estimated to be no greater than 5.9 chances per 1 million exposed 

people (ARB, 2000c). 

A cancer potency factor is the toxicity criterion, or health guidance value used for 

carcinogens, to describe the potential risk of developing cancer per unit of average daily 

dose over a 70-year lifetime. Cancer potency values are expressed as the upper bound 

probability of developing cancer assuming continuous lifetime exposure to a substance 

at a dose of one milligram per kilogram of body weight, and are expressed in units of 

(mg/kg-day)-1. The derivation of inhalation cancer potency factors takes into account 

Non-cancer 

Reference 

Exposure Levels 

(μg/m3) 

Compound Toxicological Endpoints Cancer Unit 

Risk Factor 

(μg/m3

)

-1

Cancer 

Potency 

Factor 

(mg/kg-day)-1

Acute Chronic Acute Chronic 

Perchloroethylene 

(Perc) 5.9 E-6 2.1 E-02 20,000 35 

central nervous 

system; eye & 

respiratory 

irritation 

kidney; 

alimentary 

system (liver) 

Methylene Chloride 

(MeCl) 1.0 E-6 3.5 E-03 14,000 400 central nervous system 

cardiovascular 

system; 

nervous 

system; 

Trichloroethylene 

(TCE) 2.0 E-6 7.0 E-03 None 600 none nervous system; eyes 
Technical Support Document Chapter VIII -196

the available information on pharmacokinetics and on the mechanism of carcinogenic 

action. These values are generally the 95 percent upper confidence limits on the doseresponse slope. It is a more accurate measure of a person’s chance of developing 

cancer than is the URF because it considers breathing rate and weight of the individual. 

A REL is used as an indicator of potential non-cancer adverse health effects and 

is defined as a concentration level at or below which no adverse health effects are 

anticipated. RELs are designed to protect the most sensitive individuals in the 

population by including safety factors in their development and can be created for both 

acute and chronic exposures. An acute exposure is defined as one or a series of shortterm exposures generally lasting less than 24 hours. Consistent with risk guidelines, a 

1-hour exposure is used to determine acute non-cancer impacts. Chronic exposure is 

defined as long-term exposure usually lasting from one year to a lifetime. Generally, 

hazard indices of less than 1.0 are not considered to be a concern to public health. A 

hazard index is the ratio of the modeled concentration for a toxic pollutant and the 

reference exposure level for that pollutant (ARB, 2000d). A further discussion of the 

health effects that may result from exposure to Perc, MeCl, and TCE follows. 

a. Perchloroethylene

 i. Health Impacts from Exposure to Perchloroethylene 

 Exposure to Perc may result in both cancer and non-cancer health effects. The 

probable route of human exposure to Perc is inhalation (ARB, 1997a). Table VIII-2 

presents the current health effects values that are used for determining the potential 

health impacts. 

 Perc is a potential human carcinogen with no identifiable threshold below which 

no carcinogenic effects are likely to occur. The Board formally identified Perc as a TAC 

in October 1991 (ARB, 1991b). The State of California under Proposition 65 listed Perc 

as a carcinogen in April 1988 (OEHHA, 2006). 

 

 Short-term (acute) and long-term (chronic) exposure to Perc may result in 

non-cancer health effects. Acute toxic health effects resulting from short term exposure 

to high levels of Perc may include headaches, dizziness, rapid heartbeat, and irritation 

or burns on the skin, eyes, or respiratory tract. Massive acute doses can induce central 

nervous system depression resulting in respiratory failure. Chronic exposure to lower 

Perc concentration levels may result in dizziness, impaired judgement and perception, 

and damage to the liver and kidneys (ARB, 2000d). 

 

 ii. Sources and Emissions of Perchlororethylene 

Perc is currently used in Carpet/Upholstery Cleaner; Multi-Purpose Lubricant; 

Penetrant; Sealant or Caulking Compound; and Spot Remover product. Perc is not 

currently used in any Fabric Protectant products. If Perc is not prohibited from use in 

these categories, it could conceivably be used as an avenue for compliance with the 
Technical Support Document Chapter VIII -197

proposed lower VOC limits, increasing human exposure. Emissions of Perc in these 

categories are expected to grow to 0.19 tons per day by 2010. 

b. Methylene Chloride

 i. Health Impacts from Exposure to Methylene Chloride 

 Exposure to MeCl (also known as dichloromethane) may result in both cancer 

and non-cancer health effects. The probable route of human exposure to MeCl is 

inhalation (ARB, 1997). Table VIII-2 presents the current health effects values that are 

used to determine potential health impacts. 

 MeCl is either a possible or probable human carcinogen with no identifiable 

threshold below which no carcinogenic effects are likely to occur. The Board formally 

identified MeCl as a TAC in July 1989 (ARB, 1989b. The State of California under 

Proposition 65 listed MeCl as a carcinogen in April 1988 (OEHHA, 2006). 

Short-term (acute) and long-term (chronic) exposure to MeCl may result in 

non-cancer health effects. MeCl vapor is irritating to the eyes, respiratory tract, and 

skin. It is also a central nervous system depressant including decreased visual and 

auditory functions and may cause headache, nausea, and vomiting. Acute toxic health 

effects resulting from short term exposure to high levels of MeCl may include pulmonary 

edema, cardiac arrhythmias, and loss of consciousness. Chronic exposure can lead to 

bone marrow, hepatic, and renal toxicity. MeCl is metabolized by the liver with resultant 

carboxyhemoglobin formation (ARB, 1997a). 

 ii. Sources and Emissions of Methylene Chloride 

MeCl is currently used in Multi-Purpose Lubricant; and Penetrant products. MeCl 

is not currently used in Carpet/Upholstery Cleaner; Fabric Protectant; or Sealant or 

Caulking Compound products. If its use is not prohibited in these categories, MeCl 

could conceivably be used as an avenue for compliance with the proposed lower 

VOC limit, increasing human exposure. Emissions of MeCl are expected to grow to 

0.01 tons per day by 2010. 

c. Trichloroethylene

 i. Health Impacts from Exposure to Trichloroethylene 

Exposure to TCE may result in both cancer and non-cancer health effects. The 

probable routes of human exposure to TCE are inhalation and ingestion (ARB, 1997a). 

Table VIII-2 presents the current health effects values that are used to determine 

potential health impacts. 

TCE is a probable human carcinogen with no identifiable threshold below which 

no carcinogenic effects are likely to occur. The Board formally identified TCE as a TAC 
Technical Support Document Chapter VIII -198

in October 1990 (ARB, 1990d. The State of California under Proposition 65 listed TCE 

as a carcinogen in April, 1988 (OEHHA, 2006). 

Short-term (acute) and long-term (chronic) exposure to TCE may result in 

non-cancer health effects. TCE is a central nervous system depressant. It is mildly 

irritating to the eyes and respiratory tract. Occupational exposure to TCE has resulted 

in nausea, headache, loss of appetite, weakness, dizziness, ataxia, and tremors. Acute 

exposures to high concentrations have caused irreversible cardiac arrhythmias, nerve 

and liver damage and death. Chronic exposure to TCE has also been shown to cause 

respiratory irritation, renal toxicity, and immune system depression. Alcohol 

consumption in humans increases the toxicity of TCE and causes "degreaser's flush," 

which are red blotches on the skin (ARB, 1997a). 

 ii. Sources and Emissions of Trichloroethylene 

TCE is currently used in Carpet/Upholstery Cleaner; Multi-Purpose Lubricant; 

Penetrant; and Spot Remover. TCE is not currently used in Fabric Protectant products 

and Sealant or Caulking Compound products. TCE is regulated as a VOC, such that its 

use should not increase as products reformulate to meet VOC limits. However, 

because TCE is a probable human carcinogen, we are proposing to prohibit its use in 

these categories. In 2010, this proposal will reduce emissions of TCE by 0.02 tons per 

day. 

 d. Proposed Toxics Prohibition

 In this rulemaking, staff is proposing to prohibit the use of Perc, MeCl, and TCE 

in Carpet/Upholstery Cleaner; Fabric Protectant; Multi-purpose Lubricant; Penetrant; 

Sealant or Caulking Compound; and Spot Remover products. This proposal is based 

on data suggesting that there would be potential excess cancer cases resulting from 

their use. In proposing this prohibition we are relying on previous work conducted by 

ARB staff. 

 Specifically we are relying on two previous rulemakings. To review the complete 

analyses relied upon to propose these prohibitions, the reader is referred to the 

following two documents: 

 1. Initial Statement of Reasons for the Proposed Airborne Toxic Control 

Measure for Emissions of Chlorinated Toxic Air Contaminants from 

Automotive Maintenance and Repair Activities. March 10, 2000. 

(ARB, 2000d). 

 2. Initial Statement of Reasons for the Proposed Amendments to the 

California Aerosol Coating Products, Antiperspirants and Deodorants, and 

Consumer Products Regulations, Test Method 310, and Airborne Toxic 

Control Measure for Para-Dichlorobenzene Solid Air Fresheners and 

Toilet/Urinal Care Products. May 7, 2004. (ARB, 2004b). 
Technical Support Document Chapter VIII -199

In the above listed rulemakings, staff found that use of these chlorinated 

compounds posed an unnecessary health hazard. As detailed in the March 10, 2000, 

report, modeling results showed the potential for increased cases of cancer. Because 

many alternative products were available, the ARB, in 2000, prohibited the use of Perc, 

MeCl, and TCE in General Purpose Degreasers designed for automotive use, Engine 

Degreasers, Brake Cleaners, and Carburetor or Fuel-injection Air Intake Cleaners. The 

2004 report provided the rationale for prohibiting the use of these three chlorinated 

solvents in Adhesive Removers, Contact Adhesives, Electrical Cleaners, Electronic 

Cleaners, Footwear or Leather Care Product, Graffiti Removers, and General Purpose 

Degreasers. In total, not including this rulemaking, ARB has prohibited the use of Perc, 

MeCl, and TCE in 62 categories. 

Staff has determined that the proposed prohibition is necessary to mitigate 

potential adverse impacts that would result from implementing VOC limits for these 

categories, and to ensure a level playing field among all products. 

 

 The proposed prohibition of chlorinated solvents in Carpet/Upholstery Cleaner; 

Fabric Protectant; Multi-Purpose Lubricant; Penetrant; Sealant or Caulking Compound; 

and Spot Remover is being proposed as a mitigation measure under CEQA (Public 

Resources Code section 2100 et seq.). An alternative basis for the prohibition, 

however, is the authority granted the ARB to control toxic air contaminants (TACs) 

under Health and Safety Code section 39665 et seq. This section E, comprises the 

"needs assessment" report for the prohibition on chlorinated solvents, as specified in 

Health and Safety Code section 39665. 

 Additional information to support the proposed prohibition on use of Perc, 

MeCl, and TCE in Carpet/Upholstery Cleaner; Fabric Protectant; Multi-Purpose 

Lubricant; Penetrant; Sealant or Caulking Compound; and Spot Remover are contained 

in other documents and within other chapters of this Technical Support Document. 

Information regarding sources of these TACs (sources of emissions other than what is 

discussed in this Chapter) and atmospheric persistence has already been presented in 

the Initial Statement of Reasons for the Proposed Airborne Toxic Control Measure for 

Emissions of Chlorinated Toxic Air Contaminants from Automotive Maintenance and 

Repair Activities, March 10, 2000, (ARB, 2000d). The reader is referred to this 

document for further information. 

 In each category, staff has determined that alternative compounds are available 

to successfully formulate or reformulate products. More detailed information on 

alternative products and chemicals that can be used as replacements to Perc, MeCl, 

and TCE is contained in sections contained in Chapter VI that are specific to these 

product categories. Costs for reformulating and cost effectiveness of the proposal are 

contained in Chapter VII of this report. 

In the federal Clean Air Act Amendments of 1990, the United States 

Environmental Protection Agency (U.S. EPA) identified Perc, MeCl, and TCE as 
Technical Support Document Chapter VIII -200

hazardous air pollutants (HAPs) because evidence indicated the substances may have 

adverse effects on human health or the environment. As of the writing of this report, the 

U.S. EPA has not promulgated a comparable NESHAP control measure specifically for 

consumer products containing Perc, MeCl, or TCE. The U.S. EPA has adopted 

NESHAP standards which control emissions of these HAPs from other sources. These 

other measures are described in the ATCM for AMR facilities (ARB, 2000d). 

 To summarize, staff finds that the proposed prohibition on use of Perc, MeCl, and 

TCE in Carpet/Upholstery Cleaner; Fabric Protectant; Multi-Purpose Lubricant; 

Penetrant; Sealant or Caulking Compound; and Spot Remover products is necessary to 

reduce exposure and the health risk associated with use of these compounds. Without 

control, emissions of Perc, MeCl, and TCE from these six categories would be just over 

0.20 tons per day in 2010. Staff has identified that there is a potential for increased 

chances of contracting cancer from using products containing these compounds. The 

proposed prohibitions are necessary to mitigate potential adverse impacts that would 

result from implementing VOC limits for these categories. The prohibitions would also 

align with State law that requires use of best available control technology in instances 

where no safe exposure threshold is known. 

2. Proposed Mitigation Measures Related to Greenhouse Gas 

 Emissions 

 Staff is proposing, in new subsection 94509(r)(1), that Pressurized Gas Duster 

products shall not contain a compound that has a GWP of 150 or greater. 

 In accordance with CEQA, to ensure that the VOC content of these products 

does not increase as a result of reformulation to meet GWP limits, a 1 percent by 

weight, including fragrance, VOC limit is also being proposed for Pressurized Gas 

Dusters. Also to ensure VOC exempt TAC solvents are not used, staff is proposing to 

prohibit use of Perc and MeCl in Pressurized Gas Duster products. 

3. Proposed Mitigation Measure Related to Fabric Softeners – Single 

Use Dryer Product 

Staff is proposing a new subsection 94509(s) to describe the VOC content limit 

for Fabric Softener – Single Use Dryer Product. Rather than a percent by weight limit, a 

0.05 gram of VOC per use limit is proposed. The limit is designed to ensure that the 

size of each dryer sheet does not increase. In developing the limit for these products, 

staff determined that establishing a percent by weight limit could result in product 

reformulation using larger sheets to comply. This would diminish emissions reductions 

and potentially lead to increasing the solid waste stream. Therefore, in accordance with 

CEQA, the gram of VOC per use limit is proposed. 
Technical Support Document Chapter VIII -201

F. RISK ASSESSMENT FOR REDUCED EXPOSURE TO OZONE AND TACS 

 The health risks associated with ozone exposure have been known for many 

years and are discussed in detail in Chapter IV. Studies have shown that when inhaled, 

even at relatively low levels, ozone can impact lung tissue and lung function. The 

greatest risk is to those who are more active outdoors during smoggy periods, such as 

children, athletes, and outdoor workers. Exposure to levels of ozone above the current 

ambient air standard leads to lung inflammation and lung tissue damage, and a 

reduction in the amount of air inhaled into the lungs. Recent evidence has, for the first 

time, linked the onset of asthma to exposure to elevated ozone levels in exercising 

children (McConnell et al., 2002). 

The actual lowering of health risks that would result from reducing VOC 

emissions, if the staff’s proposal were to be adopted, is not quantified in this report. 

However, qualitatively, we are able to conclude that reducing VOC emissions, because 

of their role as ozone precursors, will result in incremental improvement of the public’s 

health – whether it be in fewer incidences of asthma or hospitalizations, improvement in 

lung function, or fewer premature deaths. 

The VOC reductions from the proposed amendments are designed as partial 

fulfillment of the State Strategy for California’s 2007 State Implementation Plan. Thus, 

one can conclude that increments of progress towards attainment improve the public’s 

health. As shown in Table VIII-1, the proposed amendments to the Regulation are 

designed to achieve the maximum feasible VOC emission reduction from the categories 

proposed for regulation at this time. When fully effective, adopting the amendments 

would result in a VOC emissions reduction of about 5.8 tons per day. The impacts of 

our proposal on SOA formation are not clear, although we do not expect a disbenefit. 

 We are better able to assess the reduced health risk associated with prohibiting 

the use of the chlorinated solvents Perc, MeCl, and TCE in Carpet/Upholstery Cleaner; 

Fabric Protectant; Multi-Purpose Lubricant; Penetrant; Sealant or Caulking Compound; 

and Spot Remover products. Overall, the proposed amendments would prevent 

chlorinated solvent emissions by about 0.20 tons per day annually in 2010. It should 

also be noted that the scenarios analyzed to determine increased cancer risk evaluated 

concentrations in the outdoor air. It is likely that, in indoor environments, workers’ and 

other end-users’ chances of increased cancers would be higher from use of products 

containing these chlorinated solvents. 

 In summary, our health risk analysis shows that, by achieving these VOC 

reductions, the proposed amendments would reduce health risks posed by ground-level 

ozone by slightly lowering ambient concentrations. We predict that almost nine less 

tons per day of ozone would be formed. Moreover, exposure to probable carcinogens 

would be reduced by prohibiting the use of chlorinated TACs. 
Technical Support Document Chapter VIII -202

G. ALTERNATIVE MEANS OF COMPLIANCE 

Two alternative means of compliance with the Regulation have been developed. 

A current compliance alternative for manufacturers of consumer products is the 

Alternative Control Plan (ACP). The ACP Regulation, title 17, California Code of 

Regulations, sections 94540-94555, is a voluntary emissions averaging program. 

Under the ACP, an overall limit on the VOC content of emissions from each individual 

product in the ACP is determined. To be approved, an ACP must demonstrate that the 

total VOC emissions within the ACP would not exceed the emissions that would have 

resulted had the products been formulated to meet the VOC limit established for each 

product category. In other words, some products in the ACP could exceed the 

established VOC limits in the Regulation as long as those increased emissions were 

offset by additional products that over-comply with the established VOC limits. The 

ACP provides manufacturers with flexibility, but preserves the overall environmental 

benefits of emission reductions. 

Another compliance alternative that is available for manufacturers is the 

Innovative Products Provision specified in title 17, California Code of Regulations, 

section 94511. This provision allows a manufacturer to formulate products that exceed 

the mass-based limit specified in the Regulation for a particular product category. The 

manufacturer must demonstrate that, through some characteristic of the higher VOC 

product, its use will result in less VOC emissions compared to a representative 

complying product. This alternative is also specifically designed to allow manufacturers 

flexibility, while preserving the emission benefits of the Regulation. 

Absent use of either of these alternatives, staff is not aware of any additional 

compliance means, other than direct compliance with the proposed amendments. 

H. ENVIRONMENTAL JUSTICE 

State law defines environmental justice as the fair treatment of people of all 

races, cultures, and incomes with respect to the development, adoption, 

implementation, and enforcement of environmental laws, regulations, and policies. The 

ARB is committed to evaluating community impacts of proposed regulations, including 

environmental justice concerns. 

Consumer products are considered area sources and, as such their use is not 

focused in a particular area leading to a potential “hot spot.” Generally, use of 

consumer products is fairly uniform across the State, tracking with housing units, and 

their emissions are spread over the course of a day, rather than concentrated at a 

particular time of day. For these reasons, we do not believe that people of any given 

race, culture, or income would be more impacted than any others would. All 

Californians should benefit equally from the reduction in VOC emissions from the 

consumer product categories proposed for regulation, as well as from the prohibition on 

use of chlorinated solvents that are TACs, and the reduction in potency of GHGs. 
Technical Support Document Chapter VIII -203

Some manufacturers of Astringent/Toner products assert that regulation of these 

products would adversely affect individuals who cannot afford professional 

dermatological care. They also contend that higher VOC-containing products may be 

necessary for people of certain ethnicities to prevent scarring and/or increased 

pigmentation. ARB staff disagrees with these assertions. We have evaluated the 

claims and directions on the labels of Astringent/Toner products and researched sales 

prices of products via in-store shelf surveys and on the Internet. We found that 

complying products that make all Astringent/Toner functional claims are readily 

available over-the-counter in a variety of retail outlets. Purchase of these products does 

not require a medical prescription, and these products are not priced differently. 

Moreover, we have not found or been presented with any data that support these 

claims. Therefore, we do not believe that the regulation of Astringent/Toner would 

adversely or disproportionately impact people of any given age, race, culture, or 

income. 

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(ARB, 2000d) 

 
Technical Support Document Chapter VIII -204

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Technical Support Document Chapter VIII -205

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