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

October 15, 2012 via electronic transmission

Air Resources Board 

1001 I Street, 23rd Floor

Sacramento, California 95814

Attn: Ms. Lori Andreoni

Manager, Board Administration and Regulations Coordination Unit

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

Subject: Proposed Amendments to the California Consumer Products Regulation Pertaining to 

Automotive Windshield Washer Fluid Products; Board Agenda Item # 12-7-2

Dear Board Members:

The Consumer Specialty Products Association (CSPA)1appreciates the opportunity to offer 

comments on the California Air Resources Board (ARB) proposal to modify current regulatory 

requirements for the Automotive Windshield Washer Fluid (AWWF) product category.

2

In 

summary, ARB is proposing to expand the Type “A” area to include new areas of the State that 

are typically at higher elevations and experience freezing temperatures. In addition, ARB is 

proposing modifications intended to clarify the definition of the AWWF product category. For 

reasons detailed below, CSPA supports ARB‟s proposed modifications.

1. ARB‟s proposed modification to the definition of the AWWF product category enhances 

the overall clarity of the applicable regulatory requirements.

As a threshold matter, ARB‟s carefully constructed definitions of product categories and other 

related terms are the central component of California‟s complex and comprehensive Consumer 

Products Regulation.3 Thus, CSPA strongly supports ARB‟s proposal to consolidate all 

 

1 CSPA is a voluntary, non-profit national trade association representing approximately 

230 companies engaged in the manufacture, formulation, distribution, and sale of products for household, 

institutional, commercial and industrial use. CSPA member companies' wide range of products includes 

home, lawn and garden pesticides, antimicrobial products, air care products, automotive specialty 

products, detergents and cleaning products, polishes and floor maintenance products, and various types of 

aerosol products. Through its product stewardship program Product Care®, and scientific and businessto-business endeavors, CSPA provides its members a platform to effectively address issues regarding the 

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

2 The proposed regulation is posted on the ARB‟s website at: 

http://www.arb.ca.gov/regact/2012/cp2012/cpappa.pdf. Other relevant documents related to this 

proposed regulation are posted at: http://www.arb.ca.gov/regact/2012/cp2012/cp2012.htm.

3

See 17 CCR § 94508(a). 
CSPA Comments on Board Agenda Item # 12-7-2

October 15, 2012

Page 2 of 3

definitions pertaining to the AWWF in a single modified definition.

4

This modification will 

enhance the overall clarity of the definition for this particular product category.

The current description of Type “A” area lists: (1) specific air basins that are defined in other 

sections of the California Code of Regulations, or (2) entire counties.5 The current reference to 

specified air basins is not readily comprehensible to the public and the regulated companies. 

Therefore, CSPA supports ARB‟s proposal to include the names of the counties that comprise 

the air basins in the Type “A” area. CSPA agrees with ARB staff‟s statement that “...county 

boundaries are more readily understood than are air basins boundaries.” 6

CSPA also supports ARB‟s proposal to use the U.S. Postal Service‟s zip codes to identify the 

freezing regions of the State that are being added to the Type “A” area. CSPA agrees with the 

ARB staff‟s conclusion that zip codes “...are commonly used and understood...and their use 

would provide a practical way for manufacturers, distributors, and retailers to manage the 

distribution and sale of AWWF products into the new Type „A‟ areas.” 7

2. ARB‟s proposed modifications will promote public safety by expanding Type “A” area to 

include other parts of the state that routinely experience freezing temperatures.

During winter months, drivers in colder areas of California must contend with ice, snow and 

freezing road spray. The use of freeze-resistant pre-mixed (i.e., ready-to-use) AWWF products

enable drivers to maintain clear vision that is necessary to safely operate their vehicles. By 

expanding Type “A” area to include narrowly-defined additional parts of the state (identified by 

zip codes) that routinely experience freezing, the ARB will promote public safety by ensuring 

that drivers will be able to use freeze-resistant AWWF products.

3. ARB‟s proposed modification to the labeling requirements for dilutable 

(i.e., concentrated) AWWF products will improve safety for drivers who occasionally 

travel to areas of the state that experience freezing temperatures.

The proposed modification will allow product labels for dilutable (i.e., concentrated) AWWF 

products to include instructions informing consumers that they may follow the dilution 

instructions for Type “A” area when traveling to regions of the State that experience freezing 

temperatures.8 CSPA supports this proposed revision since it will allow manufacturers to provide 

instructions on product labels that clearly communicate the fact that drivers may legally mix 

dilutable AWWF to a specified level and thereby ensure that the product will not freeze in the 

vehicle‟s windshield washer reservoir. 

 

4

Proposed Section 94508(a)(20). 

5

See Table of Standards at 17 CCR § 94509(a). 

6 ARB, “Staff Report: Initial Statement of Reasons, Proposed Amendments to the California 

Regulation for Reducing Emissions from Consumer Products Pertaining to Automotive Windshield 

Washer Fluid Products,” (Aug. 29, 2012) at Ch. 2 p. 16. 

7

Id. at Ch. 2 p. 11. 

8

Proposed Section 94509(b)(3)(C). 
CSPA Comments on Board Agenda Item # 12-7-2

October 15, 2012

Page 3 of 3

SUMMARY AND CONCLUSIONS

CSPA supports the proposed modifications to the regulatory requirements for the AWWF 

product category. In addition to promoting public safety, the proposed amendments clarify both 

the definition and the scope of the applicable regulatory requirements for this product category.

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

Respectfully submitted,

D. Douglas Fratz Joseph T. Yost

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

Kristin Power

Director, State Affairs – West Region

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

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

Inventory Programs Branch, PTSD

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

and Emissions Inventory Programs Branch, PTSD

CSPA Air Quality Special Committee and Automotive Products Task Force

Laurie E. Nelson, Randlett Nelson Madden Associates