Comment 1 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: Reinhard

Last Name: Oppl

Email Address: ReinhardOppl@eurofins.com

Phone Number: 

Affiliation:

Subject: Low VOC determination with method 310 not very reliable

Comment:

Low VOC coatings, adhesives etc. are difficult to assess by present

method 310 using gravimetric determination of all volatiles (weight

loss during 1 hour of heating) and then subtraction of evaporated

water:

1) With low VOC products, sensitivity and accuracy go down. 

2) With high water content and low VOC content, the limited

accuracy of water determination method will overrule any findings

of the low VOC content, resulting in very bad reliability. 

3) All this is even worse for cement based tile adhesives that are

almost impossible to determine with method 310. 

4) Modern water-based products then are punished relative to

solvent-based products due to weakness of test method, which cannot

be the meaning of method 310. 

The proposed change (direct gas chromatographic determination) is

basically excellent, but it should not refer to analytical methods

dealing with completely different issues (industrial emissions, or

solid waste), when a low VOC paint specific method is available:

ASTM D6886-03. Please use ASTM D6886-03 for low VOC products. 

Best regards, Reinhard Oppl, Eurofins Product Testing A/S,

Galten/Denmark and San Ramon/California

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2009-08-17 09:38:44

No Duplicates.
Comment 2 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: Steve 

Last Name: Bunting

Email Address: sbunting@nbfd.net

Phone Number: 949-644-3353

Affiliation: So. California Fire Prevention Officers

Subject: Consumer Products Regulation Amendments-Solvents

Comment:

REF: Section 94512, "Administrative Requirements", subsection

(e), "Additional Requirements for Multi-purpose Solvents and Paint

Thinners.",(2)

The Southern California Fire Prevention Officers feel that Section

94512(e)(2)(B)1, lacks specificity and may result in tags that are

too small to adequately deliver the intended message. While our

proposed additional language will serve to standardize the message,

It does not restrict the manufacturers from using colors or logos

associated with their brand.

Tag specifications are found in other sections of the California

Administrative Code. Please see CAC Title 19, Article 9, Section

596 through 596.16

In addition, we believe that the message should be printed in at

least five languages, including, Chinese, English, Korean, Spanish

and Vietnamese.

Attachment: www.arb.ca.gov/lists/cpmthd310/2-solvent_tags_1.docx

Original File Name: Solvent tags 1.docx 

Date and Time Comment Was Submitted: 2009-08-17 15:03:57

No Duplicates.
1. Products which include an attached “hang tag” or sticker that displays, at a minimum, 

the following statement: “Formulated to meet California VOC limits; see warnings on 

label.” Hang tags and stickers shall be in accordance with the following: 

a. Hang tags or stickers shall be large enough to display the minimum statement 

printed in Chinese, English, Korean, Spanish and Vietnamese. The statement in 

each language shall be printed in a minimum of size 14 font. 

b. The color of the hang tag or sticker shall be such that the lettering or characters 

of the statement are in sharp visual contrast to the background color of the hang 

tag or sticker. 

c. Hang tags shall be attached by means of wire or plastic tie or by the use of a 

self- adhesive. A self adhesive tag or sticker may not obscure any other warning 

messages printed on the container. 

d. A hang tag may also be fastened to the container by means of the threaded cap. 

 
Comment 3 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: James

Last Name: Sell

Email Address: jsell@paint.org

Phone Number: 202 462 6272 

Affiliation: NPCA/SCCT

Subject: Auot Refinish Issues and Sought Clarifications in Proposed Multipurpose Solvent

Rule

Comment:

September 11, 2009

Dave,

Thanks for the clarification of my understanding of the proposed

rule.

“1. I would agree with the first paragraph if it were changed to

read:

To follow up on our recent telephone call, if I understood you

correctly, it is CARB’s position that solvents and reducers that

are specifically designed to be used with in a marine/pleasure

craft coating or for an automotive refinish coating are not

included in the proposed regulation of multi-purpose solvents and

paint thinners.”

If at all possible, we would like to have this formally stated by

perhaps a statement in the rule preamble of the rule, an

interpretation from enforcement, or letter.

In discussing this further with the refinish coating

manufacturers- a couple of questions continue to linger.

First there remains a great concern about what appears to be

CARB's view of treating the refinishing of vehicles as if it is not

an “industrial process”. As I have said before, there is very

little difference in the way a car is refinished and originally

painted in that paint is being applied in both operations under

controlled circumstances. The need for solvents to clean

application equipment and to prepare surfaces to be painted is the

same. The coatings themselves are also very similar. An additional

factor to consider is that refinishing of vehicles has been on

object of regulation by the districts for nearly two decades and

they have always treated it as a stationary source like they treat

the OEM automotive operations. The cleaning solvent usage is also

housed in industrial operations regulations such as Rule 1171 in

the SCAQMD. 

Also noteworthy is that in multipurpose solvent surveys conducted

by CARB, refinish coatings manufacturers were instructed to isolate

from the survey those cleaning and surface preparation solvents
that were being sold to body shops from that those that were being

made available to the general public.

Further, CARB has also indicated that because it takes place in

stationary sources setting refinish operations should not be

subject to the regulation.

“TBAc would remain exempt for industrial uses (auto-refinish

coatings (Statewide) and industrial maintenance coatings (AQMD area

only)) where is has already been delisted. The consumer product

regulations do not impose any restrictions on pollution-generating

activities that take place at stationary sources.”

http://www.arb.ca.gov/consprod/regact/cpwg2008/table2.pdf

So we respectfully request that CARB state in the preamble to the

rule as clearly as it did in the above document that refinish

operations are not subject to the regulation because auto refinish

is an “industrial use” of the solvents and moreover the refinish

operations occur at a stationary source and “consumer product

regulations do not impose any restrictions on pollution-generating

activities that take place at stationary sources.”

Further, CARB in developing and issuing a Suggested Control

Measure (SCM) for Automotive Refinish Operations explicitly treated

the operations as a stationary source operation and suggested a VOC

limit of 25 g/l for cleaning solvents and surface preparation at

such stationary source operations. If refinish operations were

subject to CARB's independent consumers products authority then

there would have been no need to issue the SCM for consideration

and adoption by the individual air districts- it could have

directly regulated the operations. 

Consequently, if one were to take the position that cleaning

solvents and surface preparation solvents used in a refinish shop

are not industrial products the question would be which regulatory

regime controls in say SCAQMD: Rule 1171 for industrial solvent

cleaning? Rule 1143 for consumer products solvents? And/or only

aspects of CARB’s proposed rule and if so which ones?

In addition to the issues stated above, there is the practical

concern for the industry’s efforts to keep such materials in the

hands of only professional users for industrial applications. 

Treating them as essentially “consumer products” in a regulatory

program undermines these industry efforts.

Finally, we need clarity on the impact of the proposed rule in air

districts where the national VOC refinish rule prevails. The

solvent borne systems used there also use comparatively higher

solvent cleaning and surface preparation materials.

We believe that the issues discussed above support the rational

that refinish operations should be treated as an industrial process

as a whole, while not trying to isolate and identify individual

activities within the process as other than industrial. Like other

industrial processes, required cleaning and surface preparation

materials in refinish shops are not generic, but are designed for

use at such operations.

I will be glad to discuss this with you further.
Sincerely,

Jim Sell

Senior Counsel

NPCA/FSCT

.

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2009-09-14 11:05:11

No Duplicates.
Comment 4 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: Gregory

Last Name: Johnson

Email Address: Non-web submitted comment

Phone Number: 

Affiliation:

Subject: Sherwin-Williams Diversified Brands

Comment:

please see attached

Attachment: www.arb.ca.gov/lists/cpmthd310/5-conscomment.doc

Original File Name: CONSComment.doc 

Date and Time Comment Was Submitted: 2009-09-15 09:44:26

No Duplicates.
August 25, 2009 

David Mallory, P.E. 

Manager, Measures Development Section 

Stationary Source Division 

California Air Resources Board 

1001 I Street, 6th Floor 

P.O. Box 2815 

Sacramento, CA 95812 

Subject: Sherwin-Williams Diversified Brands Comments on the Current Consumer Product 

Rulemaking. 

Dear Mr. Mallory: 

Sherwin-Williams Diversified Brands (S-W DBD) appreciates the opportunity to review, 

comment and participate in the development of the current proposed changes to the Consumer 

Products Regulation. We have significant concerns with one section of the proposed regulation. 

Section 94509(u) – The provisions proposed in this section would prohibit compounds with a 

Global Warming Potential of greater than 150, prohibit the use of specified chlorinated solvents, 

and limit aromatic hydrocarbons to 1% or less in Multi-purpose Solvents and Paint Thinners. 

Concerns 

1. The scope of the proposed restrictions is unprecedented. Never has a product category or 

group of product categories had a 97 percent limit reduction coupled with chemical constituent 

prohibitions of this magnitude. 

2. The restrictions proposed for global warming, chlorinated chemicals, and aromatics take 

away too many tools available to formulators. These wholesale restrictions will reduce the 

chemist ability to develop innovative new products. Aromatics are valuable due to their high 

solvency and unique molecular structure. Simply put, there are some chemicals that can only 

be dissolved in an aromatic solvent. 

3. Limiting aromatics to 1 percent was proposed for reactivity reasons. Combining a mass 

based regulation with a reactivity limitation is too confining and will eventually eliminate all the 

available technology for the category. This should not be done for any category. It should 

either be a mass based regulation or a reactivity regulation. Never both. This category would 

be very suitable for a reactivity regulation and we would recommend dropping the mass based 

proposal in favor of a reactivity limit. 

4. Restricting an entire class of chemicals such as aromatics to prevent the use of higher 

reactivity solvents within that class is a bad regulatory precedent. There are aromatic solvents 

that will be virtually eliminated that should not be restricted at all. For example, 

parachlorobenzotriflouride (PCBTF) is an aromatic solvent exempt from VOC regulation in 

California due to its low ozone reactivity. If not for this specific exemption, the proposed 
regulation would limit PCBTF to 1% in any multipurpose or thinning solvent. This extreme 

example illustrates that the premise of eliminating an entire class of chemicals in this manner is 

capricious and arbitrary. There are many non-exempt aromatic compounds with low reactivity 

that will be unnecessarily restricted. 

As stated above, we believe this category would be best regulated under a reactivity approach. 

However, if the ARB wishes to continue with a mass based regulation we strongly urge the 1 

percent aromatic restriction be dropped from the regulation. Your time and consideration of our 

input is much appreciated. 

If you have any questions or need further information please call me anytime at 216-332-1473. 

 

Best regards, 

Gregory L. Johnson 

Director Legislative Affairs 

Sherwin-Williams Diversified Brands 

Cc: Janette Brooks, ARB Stationary Source Division 
Comment 5 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: Joseph

Last Name: Yost

Email Address: jyost@cspa.org

Phone Number: 202-833-7325

Affiliation: Consumer Specialty Products Association 

Subject: Board Agenda Item # 09-8-4; Proposed Amendments to the California Consumer

Products Regula

Comment:

Attached, please find a copy of CSPA’s comments on the proposed

amendments to the existing California Consumer Products

Regulations.

Attachment: www.arb.ca.gov/lists/cpmthd310/6-

cspa_comments_on_arb_proposed_2009_amemdments_-_board_agenda_item_09-8-4.pdf

Original File Name: CSPA Comments on ARB Proposed 2009 Amemdments - Board Agenda

Item 09-8-4.pdf 

Date and Time Comment Was Submitted: 2009-09-21 08:45:57

No Duplicates.









Comment 6 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: David 

Last Name: Darling

Email Address: ddarling@paint.org

Phone Number: 

Affiliation:

Subject: NPCA/FSCT Comments 

Comment:

Attached are comments from the NPCA/FSCT. 

Attachment: www.arb.ca.gov/lists/cpmthd310/7-carb92009.doc

Original File Name: CARB92009.doc 

Date and Time Comment Was Submitted: 2009-09-21 11:33:18

No Duplicates.
September 21, 2009 

David Mallory, P.E. 

Manager, Measures Development Section 

Stationary Source Division 

California Air Resources Board 

1001 I Street, 23rd Floor 

Sacramento, CA 95814 

 RE: Proposed Amendments to the California Consumer Products 

Regulations; Board Agenda Item # 09-8-4; NPCA Comments 

Dear Mr. Mallory: 

The National Paint and Coatings Association/FSCT (NPCA/FSCT)1 submits the 

following comments on the Proposed Amendments to the California Consumer Products 

Regulations; Board Agenda Item # 09-8-4 and incorporates by reference previously 

submitted comments. 

Aromatic Limitation 

The proposed 1% limitation on aromatic compounds restricts formulation flexibility. 

Formulators need this flexibility especially given the stringent 3% limit for Paint 

Thinners and Multi-purpose Solvents. NPCA/FSCT believes that this provision is 

problematic and not necessary and that ARB delete this proposed requirement and work 

with Industry to develop reactivity-based limits. NPCA/FSCT is also concerned that this 

could and most likely will establish a precedent for other consumer products categories in 

the future. Please refer to the letter from the National Paint & Coatings Association’s 

Spray Paint Manufacturing Committee and CSA Committees for additional comments. 

 

1

 NPCA/FSCT is a voluntary, nonprofit trade association working to advance the needs of the paint and 

coatings industry and the professionals who work in it. The organization represents paint and coatings 

manufacturers, raw materials suppliers, distributors, and technical professionals. NPCA/FSCT serves as an 

advocate and ally for members on legislative, regulatory and judicial issues, and provides forums for the 

advancement and promotion of the industry through educational and professional development services. 
2

Labeling Concerns 

NPCA/FSCT is concerned the “tag” label statement are problematic in that they may 

compel manufacturers to provide “dual” Spanish language on the labels for the affected 

products. This would increase burden on the industry by forcing companies to redo their 

product labels, and discard existing labels. 

Inconsistent VOC Content Labeling 

NPCA/FSCT is concerned that if this rule is finalized as proposed, manufacturers will 

need to comply with both ARB VOC percent and SCAQMD weight-per-volume limits 

which is problematic from a compliance and labeling perspective. In addition, while ARB 

states that the standards are “virtually equivalent”, the 3% limit is probably more 

restrictive than the SCAQMD limits. Further, as proposed, manufacturers selling 

products into SCAQMD will be subject to and be burdened by four successive standards 

between January 1, 2010 and December 31, 2013. ARB should minimize burden by 

either using its authority to supersede existing district rules or modify the language in the 

proposed regulation to have ARB VOC limits for these products apply everywhere in the 

state except for the SCAQMD. 

3% Limit is Problematic 

While ARB has attempted to mitigate the increased risk of fire hazard that will result 

from the substitution of mineral spirits to acetone in this rulemaking, this risk still 

remains. This problem is actually acerbated by the fact that the aromatic restriction will limit the 

use of an alternative to acetone – PCBTF – to only 1%. NPCA/FSCT continues to be concerned 

that few effective products exist today that will meet the 3% limit, as a result we question the 

feasibility of the proposed rule. We appreciate the fact that CARB has included a technology 

review of the rule in 2012 and we are hopeful that CARB will make any necessary changes as 

needed, to the limits based on this review. 

Thank you for your consideration of these comments. Please do not hesitate to contact 

me if you have questions or need further information. 

Sincerely, 

/s/ 

David Darling, P.E. 

Director, Environmental Affairs 

** Sent via email ** 

 
Comment 7 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: Dency

Last Name: Nelson

Email Address: dln52@verizon.net

Phone Number: 

Affiliation:

Subject: Reduce VOCs on September 24

Comment:

To: Chairman Mary Nichols 

California Air Resources Board 

1001 "I" Street 

P.O. Box 2815

Sacramento, CA 95812 

Re: Reduce VOCs on September 24th

Dear Chairman Nichols: 

I applaud the California Air Resources Board's (CARB) efforts to

reduce the emissions of volatile organic compounds (VOCs) from

consumer products. 

I strongly encourage you to lead the way in reducing harmful

toxics found in consumer and industrial products, specifically

multipurpose solvents and paint thinners. By regulating and

limiting these chemicals from our products, the state of California

would again set a precedent in protecting our environment and the

health of families and workers.

VOCs endanger the health of those who come in contact with them.

We are all vulnerable to the harmful effects of these chemicals,

which are often emitted by products used where we live and work, as

well as where our children study and play.

Many children in our communities suffer from asthma, and the

chemicals emitted by consumer and industrial products, only

increase the chances of more frequent attacks or develop asthma in

the future. Workers, and others on the front lines of exposure, may

experience an increased risk of cancer or liver and kidney damage

from daily use of these toxic substances. 

As a consumer and concerned citizen, I urge CARB to adopt tough

regulations on consumer and industrial multipurpose solvents and

paint thinners.

Please take this opportunity to protect the health of our families

by significantly reducing these air pollutants that emanate from

multipurpose solvents and paint thinners.
Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2009-09-21 12:42:17

179 Duplicates.
Board Meeting Form Letter Log

Below is the Form Letter Log for cpmthd310, comment 7.

# Received From Subject Comment

Period

Date/Time Added to

Database

9 Martin, Timothy, Reduce VOCs on September 24 45 Day 2009-09-21 12:43:04

10 TOOBERT, MICHAEL, Reduce VOCs on September 24 45 Day 2009-09-21 12:43:24

11 Arnold, Frank, Reduce VOCs on September 24 45 Day 2009-09-21 12:43:43

12 Cobb, Dean, Reduce VOCs on September 24 45 Day 2009-09-21 12:44:01

13 Laieski, Caleb, Reduce VOCs on September 24 45 Day 2009-09-21 12:44:16

14 Reback, Mark, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:45:52

15 Ev, Kayla, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:46:14

16 Osorio, Herman, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:46:31

17 Matlock, KL, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:46:45

18 Rentfro, Kris, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:47:46

19 Triplett, Tia, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:49:09

20 Sanborn, Heidi, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:49:24

21 Provenzano, James, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:49:40

22 Lassiter and Family,

Robert,

Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:49:57

23 Foss, Janice, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:50:40

24 jessler, darynne, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:50:54

25 Mehrotra, Siddharth, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:51:08

26 Frank, Lee, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:51:25

27 Zelter, Gabriela, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:51:40

28 Laieski, Caleb, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:51:57

29 Murdock, Lauren, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:52:48

30 Rockey, Phil, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:53:03

31 McGill, Ron, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:53:45

32 Barrs, Sarah, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:54:00

33 Nunez, Carlos, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:54:39

Board Meeting Form Letter Log http://www.arb.ca.gov/lispub/comm/bcformltrlog.php?listname=cpmthd...

1 of 6 12/15/2010 3:09 PM
34 Sky, Kate, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:56:11

35 Flewitt, Claire, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:56:27

36 Montapert, Anthony, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:56:55

37 Tomczyszyn, Michael, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:57:11

38 Farnum, Lorna, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:58:15

39 Floyd, Kim, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:58:28

40 kramer, julie, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:59:02

41 Affonso, Jane, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 12:59:31

42 Schwartz, Don, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:14:18

43 Klosterman, Peter, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:15:13

44 Pennington, Heather, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:16:21

45 Ernst, Elizabeth, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:16:36

46 Johnson, Louise, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:16:50

47 Bechtel, Deborah, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:17:10

48 Cuff, Kermit, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:17:29

49 Brennan, Eleanor, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:19:14

50 Ryan, therese, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:19:46

51 Hsu, Bill, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:20:36

52 Clark, Donna, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:20:53

53 Fultz Stout, Laura, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:21:09

54 Gilbert, Camille, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:21:50

55 Seidman, Dr. and Mrs.

Peter,

Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:22:18

56 Fish, James, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:23:37

57 Spitz, Jon, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:24:36

58 Piner, Lisa, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:24:53

59 Kirschenbaum, Alan, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:25:08

60 Frederick, Nicholas, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:25:41

Board Meeting Form Letter Log http://www.arb.ca.gov/lispub/comm/bcformltrlog.php?listname=cpmthd...

2 of 6 12/15/2010 3:09 PM
61 Tracy, Melvin, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:26:00

62 Zelter, Daniel, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:26:15

63 Quinn, Michael, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:26:39

64 REEL, JOSEPH, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:26:54

65 Kim, Candice, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:27:20

66 Yeager, Will, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:27:57

67 Sky, Kate, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:29:21

68 Newlon, David, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:30:21

69 Perkins, Nancy, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:31:20

70 Thompson, Lawrence, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:31:33

71 Diederichs, Barbara, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:31:47

72 Hicks, Janet, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:32:01

73 Campbell, Bruce, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:32:16

74 carr, gaile, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:32:30

75 GARCIA, CESAR, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:32:46

76 Cavanah, George, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:33:00

77 Zahller, Guy, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:33:14

78 SORAGHAN, CONOR, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:33:47

79 Amato, Julie, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:34:04

80 Harmon, Zac, Reduce Toxic Emissions from Paint Thinners and Multipurpose Solvents on

September 24 45 Day 2009-09-21 13:34:20

81 Forman, Joan, Reduce VOCs on September 24 45 Day 2009-09-21 14:49:14

82 Lowery, Bryce, Reduce VOCs on September 24 45 Day 2009-09-21 14:50:06

83 Klabin, Julie, Reduce VOCs on September 24 45 Day 2009-09-21 14:51:09

84 Cooper, Richard, Reduce VOCs on September 24 45 Day 2009-09-21 14:51:56

85 Rosenstein, Richard &

Carolyn, Reduce VOCs on September 24 45 Day 2009-09-21 14:52:24

86 Anthony, Elizabeth, Reduce VOCs on September 24 45 Day 2009-09-21 14:52:59

87 Marsh, Marilynn, Reduce VOCs on September 24 45 Day 2009-09-21 14:53:45

88 Briggs, Jr., William C., Reduce VOCs on September 24 45 Day 2009-09-21 14:54:22

89 petrulias, linda, Reduce VOCs on September 24 45 Day 2009-09-21 14:55:48

90 Cruz, Marian, Reduce VOCs on September 24 45 Day 2009-09-21 14:57:49

Board Meeting Form Letter Log http://www.arb.ca.gov/lispub/comm/bcformltrlog.php?listname=cpmthd...

3 of 6 12/15/2010 3:09 PM
91 Yarbrough, Jim, Reduce VOCs on September 24 45 Day 2009-09-21 14:58:22

92 Hammond, Marcella, Reduce VOCs on September 24 45 Day 2009-09-21 14:58:46

93 Grant, Eric, Reduce VOCs on September 24 45 Day 2009-09-21 14:59:31

94 Fishman, Ted, Reduce VOCs on September 24 45 Day 2009-09-21 15:00:25

95 Fishman, Ted, Reduce VOCs on September 24 45 Day 2009-09-21 15:01:56

96 Duckert, Ken, Reduce VOCs on September 24 45 Day 2009-09-21 15:02:22

97 Estrada, Gilbert, Reduce VOCs on September 24 45 Day 2009-09-21 15:02:55

98 Wollman, Michael, Reduce VOCs on September 24 45 Day 2009-09-21 15:03:40

99 Mauer, Michael, Reduce VOCs on September 24 45 Day 2009-09-21 15:04:06

100 Tonsberg, Barbara, Reduce VOCs on September 24 45 Day 2009-09-21 15:04:36

101 Sheedy, Keenan, Reduce VOCs on September 24 45 Day 2009-09-21 15:07:15

102 Lobdell, James, Reduce VOCs on September 24 45 Day 2009-09-21 15:07:52

103 Redish, Maryellen, Reduce VOCs on September 24 45 Day 2009-09-21 15:08:16

106 Anderson, John H., Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 10:52:12

107 Mackey, Claudia, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 10:54:12

108 Ireland, Kelly, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 10:55:29

109 Hong, Celeste, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 10:56:18

110 Ledden, Dennis, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 10:57:08

111 Meyer, Twyla, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 10:57:50

112 LeBlanc, Candy, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 10:58:49

113 Marshall, RJ, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 10:59:53

114 Bowman, Jason, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:00:32

115 Bowman, Candy, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:01:10

116 Bechtel, Paul, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:01:47

117 Rubin, Michael, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:02:28

118 Gill, Ayesha, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:03:01

119 Bocchetti, Ralph, riverglen2816@yahoo.com 45 Day 2009-09-22 11:03:40

120 Sanchez, Tom, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:04:18

121 Tidwell, Amber, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:04:51

122 Vogel, Linda, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:05:23

123 Weiss, Edward, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:06:00

124 Warshaw, Lisa, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:06:37

125 Jackson, J, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:07:20

126 John, LaWana, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:07:54

127 Seltzer, Rob, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:08:28

128 Davies, Dorothy L., Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:09:05

129 Baanta, Lynne, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:09:36

130 Ibarra, Anai, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:10:34

131 Fiore, Mark J., Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:11:06

132 Chandler, Leonard B., Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:11:48

133 Miller, Harriet, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:12:38

134 DeTora, Danny, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:13:22

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135 Parker, Clark, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:13:56

136 Miller, Nancy, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:14:48

137 Rowe, Carol, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:15:25

138 Hernandez, Robin, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:16:24

139 Wilson, Jack, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:16:57

140 Beadman, H, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:17:28

141 Tuomi, Reesha, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:18:08

142 Bolman, Diane, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:18:44

143 Denton, John T., Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:19:17

144 Viken, Barbara, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:20:03

145 Schickele, Gail, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:20:40

146 Conroy, Thomas, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:22:33

147 Nuehauser, Alice, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:23:16

148 Schreyack, Claus, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:23:59

149 Estes, Douglas, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:24:33

150 Toback, Norman, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:25:12

151 Cabrales, Liz, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:25:51

152 Denison, James, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:26:28

153 Markus, Mary, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:26:57

154 Morris, Keith, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:27:33

155 Fields, Jill, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:28:03

156 Buenabad, Jose, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:28:36

157 Barry, Dwight, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:29:09

158 Essman, John, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:29:40

159 Baer, Ted, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:30:11

160 Chiang, Ben, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:30:46

161 Evans, Michael W., Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:31:16

162 Rosenfeld, Henry, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:32:05

163 Sanfilippo, Val, sanfiv@yahoo.com 45 Day 2009-09-22 11:32:29

164 Holtzclaw, John, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:33:14

165 Zentura, J, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:33:47

166 Bostick, Amy, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:34:20

167 Watts, Susan, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:35:04

168 Herndon, Laura, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:35:39

169 Lao, Fabiola, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:36:27

170 Cyr, Vicki, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 11:36:59

173 Gill, Susan, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:13:14

174 Iosif, Katherine, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:14:11

175 Brodkin, Karen, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:14:49

176 Rotcher, Michael, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:15:18

177 McCall, Daniel, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:15:54

178 Whitener, William, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:16:32

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5 of 6 12/15/2010 3:09 PM
179 Scholz, Ernest, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:17:09

180 Kelly, Nancy, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:17:43

181 Scholz, Ernest, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:22:11

182 Calhoun, Charles, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:22:53

183 Cukrov, Vince, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:23:57

184 Doi, Shari, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:24:27

185 Garciaa, Luis A., Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:27:42

186 Graffell, Jess, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:28:22

187 Fish, Margaret, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:29:09

188 Sanchez, Elba, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:29:50

189 Wyatt, Aimee, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:30:25

190 Wertheim, Lisa, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:31:18

191 Kondo, Annette, Adopt a Strong Regulation, Reduce VOCs in Consumer Products 45 Day 2009-09-22 12:32:10

If you have any questions or comments please contact COTB at (916) 322-5594.

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6 of 6 12/15/2010 3:09 PM
Comment 8 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: F.H.

Last Name: Brewer

Email Address: Non-web submitted comment

Phone Number: 

Affiliation:

Subject: S.C. Johnson & Son, Inc. 

Comment:

Please see attached. 

Attachment: www.arb.ca.gov/lists/cpmthd310/104-johnson.pdf

Original File Name: Johnson.pdf 

Date and Time Comment Was Submitted: 2009-09-21 16:43:54

No Duplicates.

Comment 9 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: Leslie

Last Name: Berry

Email Address: Leslie_Berry@americanchemistry.com

Phone Number: 

Affiliation: American Chemistry Council

Subject: American Chemistry Council Solvents Industry Groups Consumer Product Comments

Comment:

Please see attached.

Attachment: www.arb.ca.gov/lists/cpmthd310/105-acc_sig_carb_cp_comments_092209.zip

Original File Name: ACC SIG CARB CP comments 092209.zip 

Date and Time Comment Was Submitted: 2009-09-22 06:09:49

No Duplicates.
September 22, 2009

Via email

David Mallory, P.E.

Manager, Measures Development Section

Stationary Source Division

California Air Resources Board

1001 I Street, 6th Floor

P.O. Box 2815

Sacramento, CA 95812

Subject: Proposed Amendments to the California Consumer Products Regulations; Board Agenda Item # 

09-8-4

Dear Mr. Mallory:

The Solvents Industry Group (―SIG‖)1of the American Chemistry Council is pleased to provide 

the following comments on the California Air Resources Board’s (―CARB‖ or ―Board‖) Proposed 

Amendments to the Regulation for Reducing Emissions from Consumer Products and Revisions to Test 

Method 310 (―Proposed Amendments‖), as updated by CARB’s ―Staff’s Suggested Modifications to the 

Original Proposal.‖ The proposal would establish, inter alia, tiered, ultra-low, mass-based volatile 

organic compound (―VOC‖) standards for multi-purpose solvents, paint thinners and double phase aerosol 

air freshener. As solvent manufacturers that conduct business in the state of California, SIG member 

companies must be considered part of the regulated industry for this proposal. Therefore, SIG would be

significantly and negatively affected by this unbalanced proposed regulation. As discussed in these 

comments, SIG requests that CARB suspend consideration of the proposed amendments based on the 

following concerns:

Reactivity-based standards more effectively reduce the ozone-forming potential of solvent-based 

products while providing formulators with greater flexibility to produce products that meet 

performance and safety specifications.2 SIG strongly supports the adoption of reactivity-based 

standards either as the sole compliance option or at least as an alternative compliance option for 

product categories, including paint thinners and multipurpose solvents. 

CARB has not met its legal burden of demonstrating that its proposed regulations are 

commercially and technologically feasible and necessary. 

CARB’s proposed aromatics prohibition is arbitrary and capricious.

 

1

SIG represents major U.S. manufacturers of hydrocarbon and oxygenated solvents and was formed to address health, 

safety, and environmental issues affecting both the producers and users of those materials. Members of SIG include: The Dow 

Chemical Company, ExxonMobil Chemical Corporation, Shell Chemical LP, and Eastman Chemical Company.

2

See William P. L. Carter, Development of Ozone Reactivity Scales for Volatile Organic Compounds, 44 J. Air & Waste 

Mgmt. Ass’n 881 (1994); A. Russell et al., Urban Ozone Control and Atmospheric Reactivity of Organic Gases, 269 Science 491 

(1995).
Page 2 of 10

CARB CP Amendments, Sept.24, 2009

CARB has not considered and evaluated a reactivity-based approach as a reasonable alternative to 

its mass-based proposal as required by Government Code section 11346.2. 

Interested stakeholders have not had the opportunity to review and comment on the full detail of 

CARB’s 2008 Paint Thinner and MPS survey update. 

Current proposal would result in the formulation of consumer products that pose a significantly 

higher fire risk to consumers and the public. 

I. General Position

SIG has long worked with CARB, South Coast Air Quality Management District, Bay Area Air 

Quality Management District, other air quality management districts in California, and the U.S. 

Environmental Protection Agency (―EPA‖) on regulations and policies to reduce tropospheric ozone. 

SIG’s own research and investigations, as well as many other independent studies, including those 

undertaken by CARB, Dr. William Carter, the University of North Carolina, and Georgia Tech, have 

consistently concluded that the most efficient and cost effective means of regulating consumer products 

emissions and obtaining meaningful ozone reductions is through reactivity-based regulations. As is often 

the case, CARB and the State of California have been leaders in this progressive approach to regulating 

ozone. Mass-based approaches, in stark contrast, are outdated, inefficient, needlessly rigid, and 

potentially counterproductive to the overall goal of ozone reduction. SIG strongly supports the adoption 

of reactivity-based standards either as the sole compliance option or at least as an alternative compliance 

option for product categories, including paint thinners and multipurpose solvents. 

Importantly, SIG is also concerned that CARB has not met its legal burden of demonstrating that 

its proposed regulations are commercially and technologically feasible and necessary. For example, 

CARB is proposing to adopt a 3 percent tier 2 standard that it acknowledges ―has not been demonstrated,‖ 

at least for thinners, and the impacts of which cannot be ―fully assess[ed]‖ until more information is 

obtained. At the very least, CARB has not provided interested stakeholders with sufficient information to 

weigh in meaningfully on its feasibility determinations. Although the Initial Statement of Reasons 

suggests otherwise, CARB has not released the full detailed results of its 2008 survey update, which 

according to the staff report serve as the primary bases of this proposal. Before adopting a final 

amendment, CARB must afford SIG and other stakeholders with an opportunity to evaluate and comment 

on this critical information. SIG also opposes CARB’s aromatic restriction as arbitrary and capricious. If 

CARB wants to adopt reactivity concepts, it should do so completely as a sole compliance option or as an 

alternate control plan and not in a piecemeal and one-sided fashion.

SIG is disappointed that CARB has not considered and evaluated a reactivity-based approach as a 

reasonable alternative to its mass-based proposal as required by Government Code section 11346.2. 

Reactivity-based standards offer a legitimate and cost-effective alternative, and thus must be evaluated. 

Such an evaluation would reveal the benefits and superiority of reactivity standards.

SIG is also concerned, like CARB itself was during SCAQMD’s recent promulgation of Rule 

1143 that adoption of CARB’s proposal would result in the formulation of consumer products that pose a 

higher fire risk to consumers and the public. Indeed, CARB was sufficiently concerned with this issue 

that it solicited the input of the Office of the State Fire Marshall on Rule 1143 and submitted comments 

on this specific issue to SCAQMD in December 2008. Despite its expressed concerns, CARB has 

nevertheless proposed a state-wide rule that would create the same public health risk as Rule 1143. And 

although SIG supports the rule’s proposed notification and marking requirements, CARB has not 

explained or provided support for how such requirements would significantly abate the acknowledged 

public hazards that will undoubtedly result from the proposal. 
Page 3 of 10

CARB CP Amendments, Sept.24, 2009

For these and the other reasons provided below, SIG urges the Board to table its mass-based 

proposal and to instead pursue a reactivity-based approach. CARB has all the tools necessary to develop, 

implement, and enforce such an approach, and to do so now. Alternatively, SIG requests that CARB 

delay its consideration of the staff proposal until interested stakeholders have had a chance to review and 

comment on the full detail of CARB’s 2008 Paint Thinner and MPS survey update. SIG further requests

that CARB postpone consideration of its Tier 2 standards until at least 2012 when additional feasibility 

and safety data will be available.

II. Reactivity Is More Effective And Efficient At Reducing Ozone than Mass-Based 

Approaches.

Photochemical reactivity is a scientifically sound and more effective means of addressing 

tropospheric ozone. It is a better predictor of the ozone-forming potential of solvent based VOCs than 

mass-based measurements and therefore serves as a superior basis for reducing ozone formation.3 This is 

due to the varying reactivities of different solvent VOCs, which, as even CARB notes in the April 1, 2009 

workshop materials, are determinable in a laboratory and subject to peer review.4 Research demonstrates 

that VOC reactivities vary significantly, by as much as 100-fold.5 In contrast, mass-based limits 

implicitly – and erroneously – assume that all VOCs have the same potential to contribute to ozone levels. 

Because mass-based limitations create an incentive for product manufacturers to use more active (and 

often more reactive) VOCs, lowering mass-based limits also may well lead to an increase in the use of 

more reactive solvents in product formulations, limiting the effectiveness of the proposed regulations and 

in some cases, increasing overall VOC emissions on a product category basis.6 As discussed in more

detail below, although CARB’s proposal would prevent erosion of air quality gains attributable to the 

increased use of aromatics, it would not prevent formulators more generally from meeting lower massbased limits by substituting lower-reactive VOCs with higher-reactive ones. 

Mass-based limits arbitrarily set too low may force formulators to utilize highly-reactive 

compounds to achieve desired product performance that, in turn, form larger quantities of ozone than 

otherwise would have been produced. In fact, instances in which mass-based regulation yielded less-than-

 

3

See William P. L. Carter, Development of Ozone Reactivity Scales for Volatile Organic Compounds, 44 J. Air & Waste 

Mgmt. Ass’n 881 (1994); A. Russell et al., Urban Ozone Control and Atmospheric Reactivity of Organic Gases, 269 Science 491 

(1995).

4

See William P. L. Carter, Reactivity Estimates for Selected Consumer Product Compounds (Feb. 19, 2008) at Table C-1 

(listing VOCs for which ozone impact estimates are available); see also CARB, Workshop Presentation at Slide 23 (April 1, 

2009), available at http://www.arb.ca.gov/consprod/regact/tscpwg/cpworkshop04_01_09.pdf.

5 Letter from Courtney M. Price, ACC, to EPA Docket ID. No. OAR-203-0200, at 2 (Mar. 2, 2005). See also William R. 

Stockwell, Review of the Updated Maximum Incremental Reactivity Scale of Dr. William Carter, at 1 (Nov. 29, 1999) (―The 

contribution of each VOC to the formation of ozone is different because each has a different oxidation mechanism in the 

atmosphere. The ozone formation potential has been characterized by several different measures . . . .‖). 

6

See, e.g., National Volatile Organic Compound Emission Standards for Aerosol Coatings, 72 Fed. Reg. 38,952, 38,963, 

38,962 (July 16, 2007) (proposed rule) (―EPA recognizes that individual VOC can react differently in the atmosphere and can 

vary in the amount of ozone generated.‖ Furthermore, ―[I]f the VOC content limits are [set] too low manufacturers may be 

forced to use more reactive solvents to achieve comparable product performance. For example, . . . manufacturers may have to

increase the usage of toluene and xylene in order to reformulate to a higher solids coating. Both toluene and xylene are very 

reactive compounds and have the potential to form significantly larger quantities of ozone than many other solvents. If 

manufacturers use VOC with higher reactivities, it is possible that decreasing the VOC content of the coating potentially 

increases the actual ozone formation.‖). 
Page 4 of 10

CARB CP Amendments, Sept.24, 2009

satisfactory VOC emission reductions have been noted in the past.7 It is irrational to anticipate that 

formulators will simply reduce the quantity of existing VOCs in products without making substitutions to 

maintain product performance. Another unintended consequence of the Proposed Amendments would be 

reduced product performance. A reactivity-based approach, by contrast, will minimize ozone formation 

potential because formulators will not be restricted to compensating for low-VOC compound volumes 

with highly-reactive constituents. Under a reactivity-based approach, formulators will have the flexibility 

to create better performing products for the market while ensuring that atmospheric impacts from VOC 

emissions are reduced. Such an approach benefits consumers, industry, the environment, and public 

health.

If CARB’s desire is to achieve a certain overall reduction in ozone formation that is at least 

equivalent to reductions achievable through mass-based reductions, it can easily back calculate productweighted MIR limits to achieve that outcome. Such an approach would be far superior to CARB’s 

proposed mass-based standard and supplemental aromatics restriction. 

III. Reactivity-Based Standards Are Already Being Successfully Implemented By CARB.

Reactivity-based standards are already in effect in California, having successfully been 

implemented by CARB in its 2001 aerosol coatings rule. Thus, there is an existing regulatory and policy 

framework that supports the further development and implementation of reactivity-based standards.

EPA has also recognized the superiority of a reactivity-based regulatory approach, based largely 

on CARB’s own experience in the area. For example, EPA approved California’s own reactivity-based 

rule governing VOC emissions from aerosol coatings products in 2005.8 That same day, EPA issued an 

interim guidance, recommending to the states that they explore adopting reactivity-based approaches in 

their State Implementation Plans.9 EPA then adopted a reactivity-based standard for aerosol coatings in 

2008, based on California’s rule, and has recently proposed to add additional compounds and reactivity 

factors.10 

 

6 Revisions to the California State Implementation Plan and Revision to the Definition of Volatile Organic Compounds 

(VOC) – Removal of VOC Exemptions for California’s Aerosol Coating Products Reactivity-Based Regulation; Proposed Rule, 

70 Fed. Reg. 1,640, 1,648 (Jan. 7, 2005) (proposed rule) (―The CARB reported that one company intended to comply with 

stricter CARB VOC mass-based limits by using less total VOC, but also by increasing the amount of much more reactive VOCs 

to compensate for solvency needs in the product. The CARB also reported that another large company indicated that its 

compliance strategy with more stringent VOC mass limits would be to increase the aromatic content (increasing reactivity) in its 

products. In these instances, CARB points out that the increased reactivity of the VOC emissions likely reduces the benefits of 

the lower mass of VOC emissions.).

8 Revisions to the California State Implementation Plan and Revision to the Definition of Volatile Organic Compounds 

(VOC) – Removal of VOC Exemptions for California’s Aerosol Coating Products Reactivity-based Regulation, 70 Fed. Reg. 

53,930, 53,931 (Sept. 13, 2005) (final rule) (―The CARB hopes to target VOC emissions reductions to better control a product’s 

contribution to ozone formation by encouraging reductions of higher reactivity VOCs, rather than by treating all VOCs in a 

product alike through a mass-based rule.‖)

9

Interim Guidance on Control of Volatile Organic Compounds in Ozone State Implementation Plans, 70 Fed. Reg. 

54,046, at 54,046 (Sept. 13, 2005) (―[EPA] encourages States to consider recent scientific information on the photochemical 

reactivity of [VOCs]. . . .).

10 National Volatile Organic Compound Emission Standards for Aerosol Coatings, 74 Fed. Reg. 14,941 (Apr. 2, 2009) 

(proposed rule); National Volatile Organic Compound Emission Standards for Aerosol Coatings, 73 Fed. Reg. 15,604, 15,606 

(Mar. 24, 2008) (final rule) (―It is generally understood that not all VOC are equal in their effects on ground-level ozone 

formation. Some VOC react extremely slowly and changes in their emissions have limited effects on ozone pollution episodes. 

Some VOC form ozone more quickly than other VOC, or they may form more ozone than other VOC. Other VOC not only form 

ozone themselves, but also act as catalysts and enhance ozone formation from other VOC.‖).
Page 5 of 10

CARB CP Amendments, Sept.24, 2009

Despite the growing trend toward reactivity-based standards, SIG is aware that a select group of 

other stakeholders has raised concerns about the appropriateness of regulating based on reactivity. First, 

some raise the issue of ―toxicity.‖ The argument is that reactivity-based standards would result in the 

formulation of products that are more ―toxic‖ than conventional products. This argument is ambiguous 

and misplaced. 

As an initial matter, it is not clear in this context what is meant by ―toxicity.‖ Is the concern 

exposure to the general public through ambient concentrations? Or is the concern acute exposure to 

workers or consumers? Toxicity of particular compounds, by itself, provides little information about 

actual risk. If anything, the discussion should be about risk, which is a measure of toxicity, dose, and 

duration of exposure. If the concern is workplace safety for product formulators, federal and state 

workplace safety regulations would govern. If the argument is point of use exposure, consumers are 

given clear instructions for minimizing exposures through proper handling and application techniques. If 

the argument is ambient air exposure, there is simply no credible evidence that suggests that releases from 

Thinners and Solvents create toxic conditions in the ambient environment. Moreover, to the extent that 

CARB is concerned with exposure to certain chlorinated compounds, then it could adopt a reactivitybased approach that also restricts substances of concern. 

Another concern some have raised is that reactivity-based regulations will increase ambient PM2.5 

concentrations and Secondary Organic Aerosol (―SOA‖) yields. SIG is unaware of any data supporting 

that proposition. To the contrary, recent data published by the South Coast Air Quality Management 

District contradicts this assertion. Specifically, a recent CE-CERT study cited by the South Coast 

concluded that the PM formation potential of several common VOC compounds are similar to and in 

several cases lower than the ―base case.‖11 These results shed significant doubt on the assertion that 

reactivity-based rules will increase secondary PM. 

Finally, CARB has raised questions about the enforceability of reactivity-based standards, citing 

technical and cost concerns associated with sampling product off the shelf and determining compliance 

with established limits. As a practical matter, any regulation, whether mass or reactivity-based, will 

require formulators and manufacturers to comply with the law or face significant civil or criminal 

penalties (like virtually every other environmental regulatory scheme in the United States). To avoid an 

otherwise viable regulatory scheme based on the unfounded assumption that the regulated community 

will automatically try to cheat the system discredits the regulated community. In any event, it is obvious

that several recordkeeping and certification/reporting mechanisms could be adopted to address this 

concern. For example, product formulators can be required to keep very specific product formulation and 

manufacturing data, and CARB can require submission of this data at any time. If, upon review of 

submitted data, CARB were to determine that actual product sampling is required, it could perform that 

testing on a much smaller subset of products of interest. In the alternative, we are willing to work with 

CARB to develop a third-party certification system that product formulators would have to obtain prior to 

putting product on the market. Third-party certification systems are widely used in other consumer 

product settings, and can easily be adapted to MPS and thinners if necessary. CARB would also have the 

authority to independently verify compliance through product specific testing similar to the current 

enforcement scheme for CARB’s aerosol rule.

 

11 See SCAQMD draft Environmental Assessment for its proposed Rule 1143, Consumer Paint Thinners and MultiPurpose Solvents, at table 2-5.
Page 6 of 10

CARB CP Amendments, Sept.24, 2009

IV. Specific Comments.

A. CARB Must Evaluate a Reactivity-Based Option

CARB has long recognized that reactivity-based methodologies provide a reasonable alternative 

to conventional mass-based approaches. Indeed, in its 2007 comprehensive strategy (the ―Strategy‖) for 

obtaining the federal 8-hour ozone standard, CARB acknowledges that:

the ability to achieve significant reduction from mass-based standards is waning, so staff 

will likely be shifting the focus to other potential emission reduction opportunities. One 

such measure would include investigating emission reduction opportunities through 

reactivity-based standards in most categories. A reactivity-based approach relies on the 

scientific principle that different chemical compounds form different amounts of ozone in 

the atmosphere, rather than the mass-based approach that reduces ozone formation by 

reducing all reactive organic gases. . . . In the future, it is likely that further emission 

reductions from the consumer products source category will not be feasible using 

conventional approaches.12

In light of this recognition, pursuant to Government Code section 11346.2, CARB has an 

obligation to consider and evaluate a reactivity-based alternative to its current proposal. To date, CARB 

has only considered four alternatives: (1) no action, (2) different limits, (3) the setting of different 

effective dates, and (4) different limits for different categories.

13 This analysis is legally insufficient. By 

failing to evaluate reactivity, CARB has ignored by far the most reasonable alternative, one it has adopted 

for aerosol coating products. If CARB is going to reject reactivity, it has an obligation to provide its 

formal explanation for such a decision. 

SIG urges CARB to adhere to its own comprehensive Strategy and to shift its focus to a more 

progressive reactivity approach.

B. CARB’s Proposed Aromatics Prohibition is Arbitrary and Capricious 

CARB’s proposed amendments would, effective December 31, 2010, prohibit any person from 

selling, supplying, offering for sale, or manufacturing for use in California any MPS or thinner that 

contains greater than 1 percent aromatic compounds by weight. See proposed § 94509(u)(1)(c). The 

purpose of this provision is to prohibit formulators from replacing current VOC solvents used in MPS and 

thinners with ―highly reactive‖ aromatics and hence negate the reductions anticipated by the tier 1 

standards. 

This aromatic prohibition is essentially a reactivity-based provision grafted onto a conventional 

mass-based approach. SIG opposes this prohibition on several grounds. First, if CARB is going to rely 

on reactivity-based concepts, then it ought to adopt the concept in its entirety. CARB selective use of 

reactivity unfairly serves only to make the mass-based approach more onerous and denies formulators any 

of the benefits of relative reactivity. Second, at the very least, if CARB is going to rely on reactivity to 

prohibit the use of aromatics, it should also allow reactivity to serve as the basis for an alternate control 

plan. As currently drafted, a consumer product could only be eligible for an innovative products 

exemption if the manufacturer ―demonstrates by clear and convincing evidence that . . . use of the 

product will result in less VOC emissions.‖ Proposed § 94511(a). Thus, a product that emits more VOC 

 

12

 Strategy at 129.

13 Proposed Amendments to the California Consumer Products Regulation, Initial Statement of Reason Technical Support 

Document page 12.
Page 7 of 10

CARB CP Amendments, Sept.24, 2009

emissions than a representative product could not be eligible for an exception even if clear and convincing 

evidence demonstrates that its actual ozone-forming potential is lower. Such an outcome is unjustified in 

the face of CARB’s use of reactivity to ban the use of aromatics. It must also be noted that CARB uses 

reactivity to exempt low reactive compounds in this proposal. 

Finally, CARB has not adequately explained and justified the need for and scope of the aromatics 

prohibition. First, CARB has not explained why it proposes to limit the prohibition to aromatics. CARB 

offers several examples of why prohibiting formulators from using xylenes and toluene, which have MIR 

values of 7.37 and 3.97 g O3/g VOC, respectively, would ensure that reformulated products would not 

result in greater ozone generation.

14

 While this may be true, it does not explain why the prohibition is 

limited to aromatics. Many other compounds have MIR values that exceed xylene and toluene, yet they 

would not be subject to the rule’s use prohibition. It would be arbitrary and capricious for CARB to 

adopt, without adequate explanation, a ban on the use of certain higher reactive compounds (i.e.,

aromatics) yet allow other compounds with equivalent or higher MIRs to be used freely. 

In addition, in the absence of regulating based on reactivity, a formulator could choose to use 3% 

of any non-exempt VOC species, which could have an MIR up to about 20. A blend that is 97% acetone 

and 3% of a 20 MIR species would have a weighted MIR value of approximately 1.0. In effect, CARB 

has unintentionally set an upper reactivity limit of about 1.0 g ozone per gram of product, potentially 

limiting the total emission reduction to about 53% not 98.5% ozone reduction as claimed. The arbitrary 

1% limit placed solely upon aromatic compounds does little or nothing to mitigate this.

Nor has CARB provided any justification for the specific aromatic limit of one percent. How did 

CARB arrive at that number? What would be the implications of a prohibition set at some higher 

percentage, such as 2 or 5 percent? SIG requests that CARB provide this analysis and allow stakeholders 

to comment on it before finalizing the prohibition.

C. CARB Has Not Demonstrated that Its Proposed Regulations are 

Commercially and Technologically Feasible

CARB has proposed to establish a two tiered approach to regulating MPS and thinners. Tier 1 

would become effective on December 31, 2010 and limit VOCs to 30 percent by weight. The tier 2 

standard would take effect on December 31, 2013 and limit VOCs to 3 percent. California Health and 

Safety Code § 41712 provides that before CARB may adopt regulations to control VOCs in consumer 

products, it must first determine that such standards are (1) commercially and technologically feasible and 

necessary; and (2) necessary to attain state and federal ambient air quality standards. CARB has not met 

its burden here, particularly with respect to its proposed tier 2 standards.

First, SIG objects to CARB’s failure to make available the complete results of its 2008 

MPS/Thinners survey update. The absence of this information has prevented SIG and other stakeholders 

from assessing fully the feasibility and merit of CARB’s proposal. The limited data released in March

2009 included in the proposed amendments to the consumer products regulation initial statement of 

reason technical support document simply does not provide enough detail for a meaningful evaluation. 

Thus, we respectfully request that CARB make the comprehensive results of its 2008 survey available and 

allow stakeholders sufficient time to evaluate the data and comment before making any final decisions on 

the proposal.

 

14 Proposed Amendments to the California Consumer Products Regulation, Initial Statement of Reason Technical Support 

Document page 101.
Page 8 of 10

CARB CP Amendments, Sept.24, 2009

CARB staff itself makes the case that the tier 2 standards are not commercially and 

technologically feasible. For example, CARB staff state in the TSD that, ―For the second tier limit, we 

believe it has not been demonstrated that products meeting the 3 percent VOC limit will function as paint 

thinners for all solvent-borne coatings available in commerce. While we are encouraged about the future 

viability of low VOC thinners, such as soy based products, it has not yet been demonstrated that they are 

ready for introduction into the market.‖

15

 CARB staff elsewhere state that the ―overwhelming majority of 

existing products that meet the 3 percent VOC limit are formulated with pure acetone. We believe that 

the 3 percent VOC limit is challenging because products formulated with pure acetone have not been 

demonstrated to adequately thin all types of coatings.‖16 To account for this feasibility concern, CARB 

staff has proposed to undertake a technology assessment in 2012 ―to evaluate manufacturer’s progress 

toward meeting the 3 percent limit.‖ Id.

This on its face shows that CARB has not met its burden. Until CARB can conclusively 

demonstrate that its tier 2 standard is feasible for thinners, it simply cannot, as a matter of law, adopt the 

standard—at least as it applies specifically to thinners. SIG recommends that CARB table further 

consideration of its Tier 2 standards until it can complete its technology assessment in 2012.

CARB has not sufficiently demonstrated that its tier 1 standard is feasible for both MPS and 

thinners. CARB bases its conclusion that the tier 1 standards are feasible on the results of its 2008 

MPS/Thinners survey. In particular, CARB staff assert that ―18 products, representing approximately 

11.3 percent of the total Thinners and Solvent market on a sales basis, currently comply with the proposed 

30 percent VOC limit. . . . We believe that this demonstrates that the first tier VOC limit of 30 percent 

by weight can be met using existing technology.‖

17

 

However, of the 18 products that currently meet the 30 percent limit, 15 of them also meet the 3 

percent limit. Id. This in turn means that the ―overwhelming majority‖ of these products are formulated 

with pure acetone—a formulation that according to CARB has ―not been demonstrated to adequately thin 

all types of coatings.‖18 In other words, most of the existing products meeting the 30 percent limit are the 

very same acetone products for which CARB has raised efficacy concerns as it relates to the 3 percent 

limit. Thus, the same feasibility concerns exist for tier 1. Since CARB has not yet released the full 

results of the 2008 survey, SIG has no way of knowing the characteristics of the three remaining products 

and whether they have been demonstrated to adequately thin all types of coatings. 

Nor has CARB demonstrated that its proposal is necessary to attain State and federal ambient air 

quality standards. As discussed above, since CARB has not evaluated a reactivity-based option, it cannot 

be said that this CARB proposal, i.e., a mass-based approach, is ―necessary‖ as that term is used in Health 

and Safety Code § 41712. That determination cannot be made until CARB completes its comprehensive 

analysis of all available options, including reactivity.

 

15 Proposed Amendments to the California Consumer Products Regulation, Initial Statement of Reason Executive summary ES7.

16

 SIG shares CARB’s efficacy concerns. Recent studies show, for example, that acetone may not be suitable as a lacquer 

thinner and may cause ―cobwebbing‖ and ―humidity blushing‖ due to its rapid evaporation rate. Cobwebbing occurs during a 

spray application when too much of the solvent evaporates. Humidity blushing can occur after any application method, and 

results from the evaporative cooling effect of the rapidly evaporating solvent. SIG reiterates that CARB should not promulgate 

its proposal, particular the tier 2 standard, until it has confirmed that ultra-low VOC products are compatible with their intended 

uses. 

17 Proposed Amendments to the California Consumer Products Regulation, Initial Statement of Reason Technical Support 

Document page 61.

18 Proposed Amendments to the California Consumer Products Regulation, Initial Statement of Reason Technical Support 

Document page 62.
Page 9 of 10

CARB CP Amendments, Sept.24, 2009

D. CARB’s Tier 2 Standard Could Raise Public Safety Concerns

SIG shares CARB’s concern that an ultra-low, mass-based VOC standard raises public safety 

concerns resulting from the increased fire hazards of reformulated MPS/thinner products. Although SIG 

supports CARB’s proposed labeling requirements and enhanced public education generally, CARB has 

not sufficiently explained how these measures would meaningfully mitigate the increased fire risks that 

would result from the rule as proposed. SIG believes that this is yet another reason why CARB should 

delay finalizing its proposed tier 2 standard. CARB should not make any final determinations on its tier 2 

limits until it completes its proposed technology assessment in 2012. The risks to public safety are too 

great to proceed without this needed assessment.

In light of CARB’s acknowledgement that its ultra-low tier 2 standard could result in increased 

fire hazards for consumers and the public at large,

19 SIG questions how CARB staff could simultaneously

conclude that ―No significant adverse impacts were identified‖ with the proposal20. SIG requests that 

CARB reassess its preliminary conclusion on this issue. 

E. Global Warming

CARB staff also proposes to limit the Global Warming Potential of MPS and thinners to no more 

than 150. But inasmuch as CARB proposes such a limit as part of its regulatory efforts to reduce the 

ozone-forming potential of consumer products, it has an obligation to demonstrate that its proposed GWP 

limit is commercially and technologically feasible. CARB has done no such analysis here. Nor are we 

aware of an analysis of the projected actual climate benefits of the rule, which would allow for a costbenefit assessment.

SIG respectfully requests that before finalizing its GWP proposal CARB provide record support 

to demonstrate that the limit is indeed feasible and will not eliminate a product form. 

V. Conclusion

SIG urges ARB to suspend consideration of their Consumer Products amendments at its 

September 24, 2009 Board meeting in its current form. To be clear, we are not against the regulation of 

multipurpose solvents and paint thinners. On the contrary, SIG supports reasonable regulation aimed at 

securing reductions of ground-level ozone in our urban environments. SIG is, however, against illconceived regulation that places a heavy burden on industry, reduces product performance, and raises 

safety concerns, the effectiveness of which is uncertain at best. 

 

19 Proposed Amendments to the California Consumer Products Regulation, Initial Statement of Reason Executive Summary-17.

20 Proposed Amendments to the California Consumer Products Regulation, Initial Statement of Reason Executive Summary-16.
Page 10 of 10

CARB CP Amendments, Sept.24, 2009

As always, SIG appreciates the opportunity to work with CARB on regulations that may impact 

the solvent industry. SIG is also appending to these comments a white paper further explaining the role 

of reactivity as part of effective ozone control strategies for your consideration. We remain committed to 

working with the Board on the development and implementation of reactivity-based standards in 

California, and look forward to continued dialogue in this area. Thank you for considering these 

comments. If you have any questions, please contact me at (703) 741-5612 or 

Leslie_Berry@americanchemistry.com. 

Sincerely,

Leslie Berry

Solvents Industry Group Manager

Chemical Products and Technology Division

cc: Robert Fletcher, P.E., Division Chief, Stationary Source Division

Janette Brooks, Chief, Air Quality Measures Branch, Stationary Source Division

Carla Takemoto, Manager, Technical Evaluation Section, Stationary Source Division

Judy Yee, Manager, Implementation Section, Stationary Source Division

Trish Johnson, Air Quality Measures Staff Lead, 2009 Regulatory amendments

Attachment
Solvent Industry Group 

2009 

Development of an 

Effective Regulatory 

Approach Approach 

 

Control of Ozone Formation from 

Household and Commercial Product Use 

Solvents Industry Group 
Squeezing the most out of VOC control 

© 2009 American Chemistry Council All Rights Reserved 

Page 1 

The paints, cleaners, and personal care products we use to beautify and 

sanitize our homes, offices, and belongings contain a wide range of 

volatile chemicals that may be contributors to urban air pollution. These 

chemicals, known commonly as VOCs, are essential to the overall 

performance of these products. A common definition of a VOC refers to 

any chemical that is capable of entering the atmosphere and 

participating in a chemical reaction that leads to ozone formation. This 

broad definition encompasses many types of chemicals in addition to the 

VOCs used as solvents in household and commercial products. 

Although the use of solvent VOCs has been curtailed over the last 40 

years, more ozone reductions are necessary to achieve our goals of a 

safe and healthy atmosphere. The complete removal of solvent VOCs 

from the marketplace is not a practical optional, however, since the 

performance properties of many items depends on the use of some 

solvent as an aid to formulation and application. 

Enormous effort has been made in reformulating products to eliminate 

the nonessential use of solvent VOCs while retaining their properties in a 

range of applications. For the most part, these gains have been 

achieved through the nonselective removal of VOCs, regardless of their 

relative ability to react and form ozone, the main component of urban 

smog. This "shotgun" approach to VOC control, which treats all VOCs 

as equal contributors to ozone formation is no longer a viable method for 

reducing emissions. Aggressive control of VOC use in the twenty-first 

century demands the replacement of current management practices in 

favor of controls that rely on the principles of photochemical reactivity. 

This new approach recognizes that some solvent VOCs are far more 

reactive in the atmosphere than others, and that targeting the most 

reactive will achieve a far greater benefit at a lower cost. Although some 

VOC control plans utilize reactivity principles, more needs to be done to 

accelerate the conversion to a new control policy and reduce the ozone 

threat in a technically correct and environmentally sound manner. 

...... targeting those 

solvent VOCs with the 

highest reactivity is 

more effective than the 

nonselective removal 

of all VOCs 

Control of Ozone Formation from 

Household and Commercial Product Use Household and Commercial Product Use 

Development of an effective regulatory approach 
Squeezing the most out of VOC control 

© 2009 American Chemistry Council All Rights Reserved 

Page 2 

Role of VOCs in Ozone Formation Role of VOCs in Ozone Formation 

VOCs may contribute to the formation of ozone in a complex series of 

reactions that requires the presence of heat, sunlight, and nitrogen 

oxides or NOx, whose primary source is automobile exhaust. 

To reduce ozone levels in the atmosphere, both VOC and NOx 

emissions can be controlled; but, depending on their relative amounts, 

one component or the other will be the most effective target. For 

instance, in a NOx rich urban environment, the rate of ozone formation is 

directly related to the amount of VOC available. The opposite may be 

true in rural environments where VOCs are in excess and the removal of 

NOx translates into an ozone decline. 

The VOCs emitted into an urban environment come from the following 

four sources: 

• Vegetation – biogenic sources are generally important in rural 

environments, but some cities in the Southeast have major 

emissions from trees and plants. 

• Mobile – mobile emissions come from the transportation sector 

and are the result of evaporative and exhaust emissions from the 

use of on-road and off-road vehicles; including trains, planes, 

watercraft, construction equipment. 

• Stationary – Stationary these emissions are from fixed locations and 

include the fugitive releases of VOCs from industrial and nonindustrial locations that use or manufacture volatile chemicals. 

Many nonattainment 

areas are located in 

major urban hubs, 

such as Houston, Los 

Angeles, and 

Philadelphia, that are 

natural targets for 

VOC control. 
Squeezing the most out of VOC control 

© 2009 American Chemistry Council All Rights Reserved 

Page 3 

• Area – area sources of VOCs emissions include the widely 

dispersive releases associated with the use of consumer and 

commercial products. 

Although each of these sources contribute to the atmospheric burden of 

VOCs, some sources are more amenable to control than others, 

especially in an urban environment. Vegetative sources, for example, 

cannot be reasonably controlled; and cities like Atlanta where biogenic 

emissions dominate the landscape, need to extract a larger percentage 

of their VOC reductions from the remaining source categories. 

Although the relative contribution of the three major VOC sources can 

vary according to location, the pie chart for the Sacramento 

nonattainment region is reasonably representative of the distribution 

observed in many urban environments. As shown, mobile emissions are 

the dominant source of VOCs in most situations. Solvent VOC 

emissions from the three area sources categories are by comparison far 

lower, comprising about 19% of the overall total. The solvent VOCs 

emitted from individual area sources each contribute to less than 10% of 

the total emission inventory. Though the solvent VOCs from these 

product areas are not major contributors, they are a potentially 

controllable sources that are often addressed in any ozone attainment 

plan. 

Cities like Atlanta 

where biogenic 

emissions dominate, 

need to extract a 

larger percentage of 

their VOCs reductions 

from the remaining 

source categories. 

Constructing an 

emissions inventory 

from a survey of VOCs 

in the 4 major source 

categories is a crucial 

first step in the identification of potential 

control options. 

Sacramento VOC Emissions (168 tons/day)

Consumer

Products

9%

Arch. Coatings

5%

Other

5%

Auto/LightMed Duty

Trucks

34%

Other

7%

Rec. Boat

15%

Off-Road

Equip.

8%

Other

6%

Other

6%

Stationary

11% Other Mobile

29%

Area-Wide

19%

On-Road 

Mobile

41%

Coatings

 5%
Squeezing the most out of VOC control 

© 2009 American Chemistry Council All Rights Reserved 

Page 4 

The USEPA recently released figures to show that VOC emissions from 

non-biogenic sources in the US have declined by 52% in the 16 year 

period ranging from 1980 to 2006. A closer examination of this 

information reveals, however, that the majority of these gains were made 

in the early years of the program. The chart below shows that the 

reduction of VOC emissions has tailed off in recent years and that more 

moderate mass reductions can be expected in the future.

This shrinking pool of VOCs available for ozone control has important 

implications for the development of control options. Many ozone 

nonattainment areas in the East and Southwest have projected large 

shortfalls in their VOC reduction goals. This has necessitated far stricter 

emission limits on solvent VOCs to compensate for increases associated 

with population growth. These new restrictions highlight the need for 

innovative ways of thinking about the relationship between VOC use and 

ozone formation. Despite these problems, there has not been any 

attempt to systematically entertain new options for solvent VOC control. 

Ozone control in the US : a selective history Ozone control in the US : a selective history 

Limiting the creation of urban ozone through VOC control has been a 

regulatory priority for over 40 years. The first rules can be traced back 

to Los Angeles District's Rule 66, which targeted the release of many 

VOC species in an attempt to limit the formation of urban ozone. Rule 

The reduction of VOC 

emissions has tailed 

off in recent years and 

more moderate mass 

reductions can be 

expected in the future.

The California Air 

Resources Board was 

the first to pass an 

Aerosol Coatings 

regulation in 2001 that 

incorporated the 

principles of photochemical reactivity. 

1980 1985 1990 1995 2000 2005 2007 

year

0

5

10

15

20

25

30

35

VOC emissions (M tons/year)
Squeezing the most out of VOC control 

© 2009 American Chemistry Council All Rights Reserved 

Page 5 

66 was a pass/fail regulation that only considered those reactive VOCs 

considered to have appreciable ozone-formation potential. 

For nearly two decades, ozone control in the United States focused 

entirely on limiting VOC emissions. It was only after the passage of the 

Clean Air Act Amendments of 1990 that NOx became a target for future 

action. NOx regulations provided an important new tool in the fight 

against ozone pollution, since their implementation in many parts of the 

country brought far greater benefit than the control of VOCs alone. But 

because NOx controls are not as effective in urban environments, where 

the rate of ozone formation is directly related to VOC emissions, both 

ozone precursors must be subjected to control. 

The Clean Air Act Amendments also marked the beginning of an 

aggressive attempt to control solvent VOCs by identifying areas that 

were not in compliance with the national ambient ozone standard. 

Those States with ozone nonattainment areas were required to submit a 

more detailed State Implementation Plan or SIP for tackling their air 

pollution problems. A necessary ingredient to these plans was the 

requirement for a 15 percent reduction of VOC release over a 6 year 

period in those areas in moderate violation of the standard. 

To assist the States in carrying out these goals, the CAA Amendments 

required the USEPA to regulate consumer and commercial product 

categories that accounted for at least 80 percent of the solvent VOC 

emissions in nonattainment areas. Although this list of potential control 

categories was created after first considering the ozone-forming 

potential, or reactivity, of individual VOCs in each product category, 

there was no stipulation that photochemical reactivity be used as the 

basis for controlling VOC release from these sources. 

Using the list of product categories, the USEPA created two types of 

control measures that the States could utilize to limit the use and release 

of solvent VOCs. The first type of control measures were called Control 

Technique Guidelines or CTGs, which are not regulations but 

recommendations that target facilities using large amounts of VOCcontaining products whose composition can be controlled through 

arrangements with the supplier. Since 2006, CTGs have been issued 

for 12 VOC categories. Some CTGs specify solvent VOC content limits 
Squeezing the most out of VOC control 

© 2009 American Chemistry Council All Rights Reserved 

Page 6 

for products, but most identify emission limits for the application of a 

particular type of coating. The second type of control measures are 

rules, which are aimed at the manufacturers of consumer and 

commercial products. These EPA rules are applied to products that are 

in use by the general public rather than industrial facilities. Once 

implemented, they apply nationwide and can affect those living in both 

attainment and nonattainment areas. Rules have been issued for 5 

product categories. 

• Consumer products 

• Architectural coatings 

• Automobile refinish coatings 

• Portable fuel containers 

• Aerosol spray paints 

Although ozone contribution to air pollution is indisputable, the methods 

used to control VOC release from consumer products have been the 

subject of considerable debate for many years. Two alternatives are 

available to State and Federal regulators: 

i ) treat all reactive VOCs as equal contributors to urban smog 

without any consideration of relative impact ( mass-based 

approach ) ; or 

ii ) Encourage industry to reformulate to the VOC species which 

have the least potential for ozone formation ( reactivitybased approach ) . 

Traditionally, solvent VOCs have been regulated using mass-based 

controls that limit the mass percentage of VOCs in various products or 

formulations, such as paint. Under this approach, VOCs are either 

considered reactive, and therefore subject to VOC regulation, or 

negligibly reactive, and thus exempt from control. Negligibly reactive 

compounds are compounds that, based on USEPA studies, contribute 

minimally to ozone formation. This list of compounds ( often referred to 

as VOC exempt compounds ) was established by USEPA and can be 

modified by regulation. 

The rules for consumer 

products and 

architectural coatings 

were created in 1997 

and are in the process 

of being updated. 
Squeezing the most out of VOC control 

© 2009 American Chemistry Council All Rights Reserved 

Page 7 

Mass-based limits, which are relatively easy to issue and implement 

have been the avenue of choice for developing new control regulations 

based on their long history of use. A mass-based approach treats all 

non-exempt VOCs alike in their ability to generate ozone. However, 

solvent VOCs vary significantly in their ability to impact ozone levels. 

Despite the fact that mass-based controls are rapidly becoming 

ineffective, many State regulatory authorities have adopted the position 

that reactivity will only be considered as a VOC control option once 

mass-based opportunities have been exhausted. Although both types of 

controls have their own advantages and disadvantages, recent events 

suggest that mass-based controls are becoming ineffective and going 

forward significant benefits are more realistically achieved with 

widespread adoption of reactivity-based controls. 

 

Diminishing returns from current policies Diminishing returns from current policies 

State compliance with the Clean Air Act is no easy matter. Preparation, 

submission, and approval of a SIP for bringing nonattainment areas into 

compliance with air pollution standards can take up to 3 years to 

complete. State agencies are often faced with proposing dozens of 

control methodologies for both VOC and NOx in a single action plan. In 

addition, SIPs contain a reasonable further progress provision that 

mandates a yearly reduction of VOC and NOx in nonattainment areas. 

In the face of these requirements, State authorities often need to 

develop VOC control options that go above and beyond those proposed 

by the USEPA. 

The California Air 

Resources Board is 

currently considering 

the use of reactive 

measures in 

rulemaking for 

hairspray and nail 

coating products. 

0.5 1.0 1.5 3 4 2 5 6 9 7 8 

Esters 0.1-1.2 

Aliphatics 0.4-2.7 

Alcohols 0.4–3.4

Ketones 0.4-4.3 

Glycol Ethers 

1.8-3.8 

Aromatics 4.0-9.0

Incremental Reactivity Value 
Squeezing the most out of VOC control 

© 2009 American Chemistry Council All Rights Reserved 

Page 8 

There is an initial appeal in adopting control plans that require the least 

amount of up front effort. Under these circumstances, the preferred 

approach to VOC control in the consumer and commercial product 

sector has been mass-based emission or content limits. Though this 

approach at first appears to respond to the problem of VOC control, 

there are numerous pitfalls, the most important of which is that massbased controls are not an effective means of lowering ozone levels in 

urban environments. 

The following list cites some of the most serious problems with the use 

of mass-based limits in a control scheme for solvent VOCs. In 

particular, mass-based controls: 

• do not utilize the latest scientific knowledge and allow the 

continued use of inaccurate and outmoded chemical "lumping" 

techniques to group VOCs into a few discrete chemical groups; 

• have become increasingly expensive to implement and comply 

with as the reservoir of controllable solvent VOCs is diminished; 

• do not provide manufacturers with enough options to reformulate 

their products in a manner that will preserve performance under 

all use conditions; 

• are arguably at variance with Section 183e of the Clean Air Act, 

which requires the use of the "best available control" measures 

to achieve attainment; 

• stifle innovation and product improvement by needlessly 

restricting solvent VOC content rather than VOC hazard; 

• promotes the use of an exempt category of VOCs that is 

mistakenly believed to lack any ozone forming potential; 

• are based on the mistaken belief that they are actually reducing 

urban ozone levels in all circumstances when recent evidence 

shows the ozone-forming potential of products is increasing. 

A recent analysis of the results from a solvent survey conducted before 

and after the implementation of mass-based controls in California has 

confirmed what many leading authorities have long suspected, that 

mass-based regulations do not reliably reduce ozone forming potential 

Mass-based controls 

have become increasingly expensive to 

implement and comply 

with as the reservoir of 

controllable VOCs is 

diminished. 

The number of 

counties in nonattainment increased from 

85 to 345 with the 

passage of the new 

ozone air quality 

standard in 2008. 
Squeezing the most out of VOC control 

© 2009 American Chemistry Council All Rights Reserved 

Page 9 

and can in fact promote the use of more reactive VOC species. This 

may seem to be at odds with SIP requirements which stipulate that the 

value of all recommended control measures be substantiated using 

sophisticated urban airshed models. It must be recognized, however, 

that the urban airshed models used to predict the impact of these control 

measures simplify the chemistry and reactivity of the available VOCs by 

grouping them into a few discrete categories. These oversimplifications 

can easily distort the true picture and predict an ozone benefit when 

none actually exists. 

Information presented at the VOC Reactivity Technology Forum and 

Roundtable Discussion sponsored by the South Coast AQMD has 

indicated that the ozone-forming potential of many coating categories is 

actually on the rise. The increase is the result of an overreliance on 

mass-based standards, which has allowed formulators to select solvents 

based on solvent strength, not on their actual environmental impact. 

This lack of true control has led to most categories not achieving the 

ozone reduction touted by the mass-based VOC adjustment, and in 

many cases the ozone formation from the coating category actually 

increased despite a reduction in VOC mass. While some of that 

increase in ozone forming potential is due to volume growth in the 

category, a large portion of it is due to a demonstrable increase in the 

reactivity of the solvents being selected. This unintended consequence 

of mass-based controls, becomes more severe as the reservoir of 

potentially controllable solvent VOCs in the product becomes smaller. 

A need for new pollutant control ideas A need for new pollutant control ideas 

Pollution control regulations in the US have targeted the use and release 

of solvent VOCs from consumer and commercial products for many 

years, but the era of fast and easy gains on the ozone problem are 

quickly coming to an end. The need for new ingenuity and insight into 

the problems of urban air pollution has never been greater. There is no 

better example of the increased demands being placed on VOC control 

policy than the predicted impact of the new national ambient air quality 

standard for ozone. 

VOC Reactivity Technology Forum and 

Roundtable Discussion 

September 25, 2007, 

South Coast Air 

Quality Management 

District Headquarters 

Diamond Bar, CA. 

In the face of ever 

stricter ozone 

standards and the 

impacts of global 

warming, the issue of 

VOC control needs to 

be reexamined at all 

levels of government. 
Squeezing the most out of VOC control 

© 2009 American Chemistry Council All Rights Reserved 

Page 10 

The recent reduction of the 8-hr ozone standard from 80 to 75 parts per 

billion is projected to put 4 times as many counties into ozone 

nonattainment. Those States affected by the new standard are required 

to file new SIPs by the year 2013. This will generate an even greater 

demand for novel VOC control methods, especially in urban areas where 

ozone concentrations are particularly high. 

In fact, there are concerns that we may never be able to achieve total 

control of urban ozone because of the impacts from global warming. 

Studies have shown that rising greenhouse gas emissions have caused 

a temperature increase that will adversely affect our attempts to control 

ozone in polluted environments. In effect, these studies suggest that 

large increases in the emission of biogenic VOCs will accompany a shift 

in the chemistry of smog formation. Together, these changes will lead to 

an increase in the regional background concentration of ozone. Climate 

change will also affect the intensity and duration of stagnant air episodes 

in urban areas and cause more prolonged periods of elevated ozone. 

The dual impacts of climate change and new ozone control standards 

mandate that agencies take a new approach to VOC control that will 

maximize environmental improvement opportunities and minimize the 

burden to commerce, the community, and the economy.

 

 

The Reactivity 

Research Working 

Group ( RRWG ) was 

organized in 1998 to 

conduct research and 

develop an improved 

scientific basis for 

reactivity-related 

regulatory policies. 

 
Squeezing the most out of VOC control 

© 2009 American Chemistry Council All Rights Reserved 

Page 11 

Reactivity: a rational alternative Reactivity: a rational alternative 

VOC control policy in the US has not managed to stay abreast of 

advances in the science of photochemical reactivity. For many years 

now scientists, manufacturers, and pollution prevention advocates have 

argued for the use of reactivity scales in new policy initiatives. 

Regulating chemicals according to their ability to contribute to ozone 

formation has the potential for dramatically impacting urban ozone 

levels. The adoption of this new approach has met with considerable 

resistance, however. Although some rules have been passed at the 

State and Federal level that incorporate the principles of reactivity, there 

has been a belief by many that the old mass-based controls provide 

greater benefit. 

The current philosophy seems to be that reactivity should not be 

considered until all opportunities for mass-based controls have been 

exhausted. But this policy of forcing ever tighter restrictions on the use 

of solvent VOCs is shortsighted and ignores the benefits that can be 

accrued when reactivity is used early in the process. It is based entirely 

on the belief that as long as manufacturers can reformulate, mass 

reductions are the best option. Indeed, the recent passage of the 

photochemical reactivity-based Aerosol Coatings Rule by the State of 

California was only possible after first determining that product 

reformulation was not an option. The USEPA has also published a 

photochemical reactivity based Aerosol Coatings Rule that is anticipated 

to be finalized in 2009. 

Evidence exists that 

mass-based reformulation has resulted in 

products with a higher 

ozone formation 

potential than their 

predecessors. 

The USEPA ’ s 2005 

Interim Guidance 

encouraged states to 

consider recent 

scientific information 

on reactivity in the 

development of their 

SIPs. 

VOCs are not all alike... some react faster than ot VOCs are not all alike... some react faster than others some react faster than others 
Squeezing the most out of VOC control 

© 2009 American Chemistry Council All Rights Reserved 

Page 12 

Under some circumstances mass-based reductions would seem to be a 

reasonable alternative, if there was a method to ensure that the VOC 

decreases were equally distributed among high and low reactivity 

solvents. This would ensure that the mass reductions actually resulted in 

a decline in ozone formation. Unfortunately, this is not always the case, 

and there is no guarantee that the products of tomorrow will actually 

achieve the desired result of lowering urban ozone levels. 

As noted earlier, evidence presented at the VOC Reactivity Technology 

Forum and Roundtable Discussion showed that mass-based 

reformulation has resulted in products that have a higher ozone 

formation potential than their predecessors. This unanticipated effect 

occurs because product designers have seen a performance advantage 

when low reactivity VOCs are preferentially removed from reformulated 

products. The result is an increased percentage of highly reactive VOCs 

and an overall greater ozone-forming potential for the product. Adopting 

a reactivity-based VOC control policy would prevent this unintended 

effect and ensure that all product reformulations actually result in a 

benefit to the environment. The continued push for mass reductions 

from consumer and commercial product categories does not guarantee 

that urban ozone levels will actually decline. 

A shift in VOC control policy to a scheme that promotes the use of 

reactivity-based limits would have a number of ancillary benefits that 

should also be considered. These include: 

• easier prioritization of potential control measures using reactivity 

metrics; 

• the identification of more cost-effective approaches to solvent 

VOC control; 

• the development and use of more robust urban air shed models 

to identify control options and track progress on ozone 

attainment; 

• an incentive to further speciate emissions inventories, which 

allow a more accurate identification of potential control VOC 

options; 
Squeezing the most out of VOC control 

© 2009 American Chemistry Council All Rights Reserved 

Page 13 

• the creation of more substitution options for product formulators 

resulting in more effective and efficient products.

Although some criticisms have been levied against the use of reactivitybased standards, they are generally speculative and easily addressed in 

any future policy initiatives. For instance, the claim that reactivity-based 

controls will allow greater use of less reactive, but highly toxic, solvents 

is difficult to substantiate, since manufacturers routinely screen and 

eliminate highly hazardous chemicals from their product formulations. 

Another criticism that has been cited is the belief that reactivity-based 

controls will lead to greater use of low reactivity VOCs that can be 

transported out of an area only to cause downwind increases in ozone 

formation. Studies have shown, however, that this is not the case and 

that the ozone reductions realized by the upwind elimination of highly 

reactive VOCs are far greater that the increases resulting from 

downwind formation. 

In the face of increasingly difficult compliance demands on State 

governments, reactivity-based controls provide a scientifically vetted and 

highly innovative approach to VOC control. The path has been cleared 

for the incorporation of reactivity metrics into State pollution control 

plans. The primary roadblock to widespread adoption is the failure to 

fully understand and appreciate the relative strengths afforded by this 

state-of the art approach to ozone abatement. The sooner these 

advantages are recognized, the faster we can realize real improvements 

in urban ozone levels throughout the country. 

Summary 

The current approach to the control of solvent VOCs focuses on massbased reductions to extract as much VOC as possible from a product 

category before looking at the feasibility of using reactivity-based 

controls. This tactic, however, can have negative environmental 

consequences by forcing product formulators to select alternative VOCs 

without any regard to their ozone-forming potential. This trend was 

recently illustrated at the VOC Reactivity Technology Forum where an 

analysis of past regulatory initiatives showed that strict reliance on mass

-based VOC controls has led to an overall increase in the ozone-forming 

potential of some products as manufacturers choose more efficient, but 

more highly reactive, VOCs to reformulate their products. The failure to 

adopt reactivity-based controls on a wide spread basis represents a 

The first step in 

designing a regulation 

based on reactivity is 

to select the most 

appropriate reactivity 

scale. 

VOC Reactivity Technology Forum and 

Roundtable Discussion 

September 25, 2007, 

South Coast Air 

Quality Management 

District Headquarters 

Diamond Bar, CA. 
Squeezing the most out of VOC control 

© 2009 American Chemistry Council All Rights Reserved 

Page 14 

missed opportunity that could yield far greater environmental benefit 

than the present approach. 

Drawbacks in the current VOC control policy can be prevented with a 

more aggressive move towards a reactivity-based VOC control plan at 

both the regional and national level. State agencies in charge of 

pollution planning must become more willing to entertain alternatives to 

the rigid and restrictive nature of the mass-based measures currently in 

use. Adoption of a more robust and technically justified reactivity 

scheme provides an alternative that can reap benefits far into the twenty

-first century. 

 

Over twenty different 

photochemical reactivity scales have been 

developed to meet any 

particular regulatory 

need. 
Squeezing the most out of VOC control 

© 2009 American Chemistry Council All Rights Reserved 

Page 15 

Reading List Reading List 

The following reading list provides more information on many of the topics 

discussed in this white paper. 

Avery, R. J. ( 2006 ) . Reactivity-based VOC control for solvent products: More 

efficient ozone reduction strategies. Environmental Science & Technology 40, 

4845-4850. 

Carter, W. P. L. ( 1994 ) . Development of ozone reactivity scales for volatile 

organic compounds. Journal of the Air & Waste Management Association 44, 

881-899. 

Environmental Protection Agency ( 2005 ) . Interim Guidance on Control of 

Volatile Organic Compounds in Ozone State Implementation Plans. Federal 

Register 70, 54046-54051. 

Environmental Protection Agency ( 2008 ) . National Volatile Organic 

Compound Emission Standards for Aerosol Coatings; Final Rule. Federal 

Register 73, 15604-15631. 

Luecken, D. J., and Mebust, M. R. ( 2008 ) . Technical challenges involved in 

implementation of VOC reactivity-based control of ozone. Environmental 

Science & Technology 42, 1615-1622. 

Nam, J., Webster, M., Kimura, Y., Jeffries, H., Vizuete, W., and Allen, D. T. 

( 2 008 ) . Reductions in ozone concentrations due to controls on variability in 

industrial flare emissions in Houston, Texas. Atmospheric Environment 42, 

4198-4211. 

National Academy of Science ( 1992 ) . Rethinking the Ozone Problem in 

Urban and Regional Air Pollution. National Academy Press. Washington, D.C. 

Rector, D. ( 2005 ) . Controlling Reactivity to Achieve Greater Reductions in 

Ozone-Forming Potential VOC Reactivity Technology Forum and Roundtable 

Discussion September 25, 2007. South Coast AQMD Headquarters Diamond 

Bar, CA. 

Roth, P. M., Reynolds, S. D., and Tesche, T. W. ( 2005 ) . Air quality modeling 

and decisions for ozone reduction strategies. Journal of the Air & Waste 

Management Association 55, 1558-1573. 

Russell, A., Milford, J., Bergin, M. S., McBride, S., McNair, L., Yang, Y., 

Stockwell, W. R., and Croes, B. ( 1995 ) . Urban ozone control and 

atmospheric reactivity of organic gases. Science 269, 491-495. 9

Please visit 

www.americanchemistry.com/

solvents for more information about 

other solvent topics. 

This article may be reprinted in its 

entirety, non-commercially, if the 

following statement appears: 

“Reprinted with permission from the 

American Chemistry Council.” 

Solvent Industry Group 

Members 

The Dow Chemical Company 

www.dow.com 

ExxonMobil Chemical 

Company 

www.exxonmobilchemical.com 

Shell Chemical LP 

www.shell.com 

Eastman Chemical 

Company 

ww.eastman.com 
Comment 10 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: Doug

Last Name: Raymond

Email Address: djraymond@reg-resources.com

Phone Number: 440-474-4999

Affiliation: WM Barr & Comapny, Inc.

Subject: NAA Comments on Consumer Product Amendments Board Agenda #09-8-4 

Comment:

These comments go along with a DVD that will be distrubuted.

Attachment: www.arb.ca.gov/lists/cpmthd310/171-skmbt_c35309092016470__3_.pdf

Original File Name: SKMBT_C35309092016470 (3).pdf 

Date and Time Comment Was Submitted: 2009-09-22 11:55:59

No Duplicates.






Comment 11 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: Doug

Last Name: Raymond

Email Address: djraymond@reg-resources.com

Phone Number: 440-474-4999

Affiliation: The National Aerosol Association

Subject: NAA Comments on Consumer Product Amendments Board Agenda #09-8-4 

Comment:

Please find attached comments on behalf of the National Aerosol

Association (NAA). Thank you.

Attachment: www.arb.ca.gov/lists/cpmthd310/172-

naa_comments_on_arb_proposed_board_agenda_item_09-8-4.doc

Original File Name: NAA comments on ARB proposed Board Agenda Item 09-8-4.doc 

Date and Time Comment Was Submitted: 2009-09-22 11:58:59

No Duplicates.
1

September 22, 2009 

Clerk of the Board 

California Air Resources Board 

1001 I Street 

Sacramento, California 95814 

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

Subject: Comments on Consumer Product Amendments Board Agenda #09-8-4 

Dear Clerk of the Board, 

The National Aerosol Association (NAA) represents marketers, manufacturers and suppliers in the 

US aerosol industry. NAA is the only national trade association focused solely on the aerosol 

product form. The NAA has a long history of working cooperatively with the Air Resources Board 

(ARB) on past rulemakings dealing with Consumer Products. NAA’s goal is to provide ARB staff 

with the required emission reductions while maintaining safe and efficacious aerosol products for 

the consumer. 

 

 NAA appreciates the opportunity to comment on the ARB’s proposed amendments to the 

Consumer Products Regulation. After reviewing the proposed amendments, the NAA has the 

following comments in four areas of concern that need to be addressed. Our comments will focus 

on the following areas. 

1. Lack of a Reactivity Regulation for Multi-purpose Solvents and Paint Thinners. 

2. The inclusion of an “aromatic” restriction. 

3. Restriction of Global Warming Potential for Double Phase Air Freshener aerosol. 

4. Increased Fire Risk to consumers for the 3% VOC limit. 

Reactivity Concept

NAA has been an active supporter of the science of reactivity. NAA was the first association to 

support ARB in the adoption of the Aerosol Coating regulation in 2000. While the Multi-purpose 

Solvent and Paint Thinner amendments do not effect aerosols, NAA is disappointed that the 

concept of reactivity was not used when regulating these categories. The use of reactivity would 

have provided known emission reductions while providing flexibility to the manufacturer. 
2

NAA Comments on Board Agenda Item #09-8-4 

September 21, 2009 

Page Two 

Aromatic Compounds Restriction

The inclusion of the aromatic compounds restriction would not be necessary if the concept of 

reactivity was utilized. In addition, the aromatic compounds restriction does not accomplish the 

staff goal of reducing all high reactive alternative compounds. While some aromatic compounds 

are high in reactivity, there are numerous other compounds which are high in reactivity and are not 

aromatic. Lastly, the definition for aromatic compounds is overly broad and will be difficult to verify 

through testing. Staff should remove this restriction and focus on improvements for a reactivity 

regulation. 

Global Warming Potential (GWP)

Staff has proposed a GWP restriction on Double Phase Air Freshener aerosols. Currently only one 

non flammable propellant remains that could be utilized in this category. That propellant is HFC134a. The GWP restriction eliminates the possible use of this compound. If there is a need for a 

non-flammable product in this category, industry has no alternatives. Staff should consider 

language to provide an exemption for this situation if it were to occur in the future. 

Increased Fire Risk from 3% VOC Limit.

NAA supports other commenters that the staff’s 3% proposed VOC limit will force manufacturers to 

use the exempt compounds which are extremely flammable. These compounds when added to a 

coating product will create an extremely flammable mixture and drastically increase the fire hazard 

to the consumer. 

Recommendations

Staff should remove the 3% limit and aromatic compounds restriction and focus on adopting 

reactivity based regulation. A reactivity regulation will also remove the increased fire risk issue. 

In addition, staff should include wording to exempt Double Phase Air Freshener products which 

may need to use a non-flammable propellant in the future. 

NAA appreciates the opportunity to comment and I can be reached at 440-474-4999 or at 

djraymond@reg-resources.com with any questions. 

On behalf of NAA 

Doug Raymond 
Comment 12 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: Larry 

Last Name: Greene

Email Address: lgreene@airquality.org

Phone Number: (916) 874-4802

Affiliation: SMAQMD

Subject: Comments on the Proposed Amendments to the California Consumer Products

Regulations

Comment:

See attached letter dated 9/22/09.

Attachment: www.arb.ca.gov/lists/cpmthd310/193-

david_mallory__carb_re_1291_comments_on_arb_consumer_product_regulation__2_.doc

Original File Name: David Mallory, CARB re 1291_Comments on ARB Consumer Product

Regulation (2).doc 

Date and Time Comment Was Submitted: 2009-09-22 16:25:10

No Duplicates.
September 22, 2009 

Mr. David Mallory 

Manager, Measures Development Section 

California Air Resources Board 

1001 I Street 

Sacramento, CA 95812 

RE: Comments on the Proposed Amendments to the California Consumer 

Products Regulations 

Dear Mr. Mallory: 

Thank you for the opportunity to comment on the California Air Resources 

Board's proposed amendments to the California Consumer Products 

Regulations. We commend and support the efforts to develop this regulation 

which achieves significant emissions reductions. The proposed regulation is 

written in a clear and detailed manner and provides the needed emissions 

reductions committed to in the recently adopted State Implementation Plan for 

the Sacramento region. 

We request clarification regarding the legal standing of our Rule 466 - Solvent 

Cleaning, following the effective date of this Consumer Product Regulation, 

considering the provisions of California Health and Safety Code Section 41712(f), 

which prohibits districts from adopting consumer product regulations that are 

different from a regulation adopted by the state board for that purpose. 

Rule 466 - Solvent Cleaning, was originally adopted May 23, 2002, and was 

recently amended September 25, 2008. Rule 466 applies to consumer products 

and contains a cleaning solvent VOC content limit of 50 grams VOC per liter that 

is currently effective, and a 25 grams VOC per liter limit that becomes effective 

on September 25, 2009. The proposed state regulation specifies a multi-purpose 

solvent limit of 30% VOC by weight effective December 31, 2010, and a 3% VOC 

by weight effective December 31, 2013. 

We would like clarification in ARB's rulemaking record on two points: 

1. We believe ARB's 3% limit is virtually equivalent to our Rule 466 25 gram 

limit, even though it is stated in different numerical units. Does ARB agree 

that District Rule 466 is consistent with the proposed regulation and 

41712(f)? 
Mr. David Mallory, CARB - 2 - September 22, 2009 

Re: California Consumer Products Regulations 

2. ARB has indicated that South Coast's Rule 1143, which will implement 

ARB's 2013 3% limit in 2010, is not affected by the ARB rulemaking, even 

though the deadlines for compliance are different. The same issue is 

raised by the District's September, 2009 implementation of its 25 gram 

VOC limit. Does ARB agree that the early implementation of the new limit 

under our Rule 466 is consistent with 41712(f)? 

We urge the California Air Resources Board to adopt the regulation at its 

September 24, 2009 hearing. If you have any questions regarding this comment, 

please contact me or Brigette Tollstrup at (916) 874-4832. 

Sincerely, 

Larry Greene 

Executive Director/Air Pollution Control Officer 

c. Mr. Robert Fletcher, ARB 

 Ms. Janette Brooks, ARB 

 Ms. Brigette Tollstrup 
Comment 13 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: Daniel

Last Name: Tennant

Email Address: dantw1@yahoo.com

Phone Number: n/a

Affiliation: none

Subject: elimination of 

Comment:

The elimination of emissions of consumer products, that strikes at

what every person in this state uses and sells. I don't know what

this is aimed at, but I see the price of every product in this

state going up, while the wind blows China's pollution to our

shore.

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2009-09-22 23:54:16

No Duplicates.
Comment 14 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: Heriberta

Last Name: Sandoval

Email Address: anjalid@seiulocal1877.org

Phone Number: 

Affiliation:

Subject: Reduce VOCs to protect workers

Comment:

Heriberta Sandoval,

11703 Pioneer Blvd #20

Norwalk, CA 90650

September 24, 2009

Mary Nichols

Chairman

California Air Resources Board

1001 “I” Street

P.O. Box 2815 

Sacramento, CA 95812

Dear Chairman Nichols:

I want to thank your agency’s staff for your efforts to reduce

emissions of volatile organic compounds (VOCs) and protecting the

health of workers like me. 

I am addressing you as a janitor who has been cleaning

supermarkets for more than 15 years, as well as a concerned parent

and consumer. I want to encourage your staff to continue working

hard to reduce more toxic chemicals from products like

multi-purpose solvents and paint thinners.

I am very committed to my job and I work hard to keep these

supermarkets clean and open every day. However, on a daily basis I

have to use harsh chemicals to clean the store. These chemicals

and cleaning products cause a lot of damage – sometimes corroding

my shoes and clothes. My co-workers and I constantly get headaches,

nose bleeds, eye irritations and burns to our hands. Some janitors

have developed serious asthma and other breathing problems. 

I strongly encourage you to support your staff by setting the VOC

limit to 3% and ask you to move the implementation date for

multi-purpose solvents to 2012. Many products in the market already

emit only 3% of VOCs. We believe that by moving the date for

multi-purpose solvents, CARB will reduce the health impacts

associated with the misuse of these products at our work places.

Finally, I would like to remind you that janitors like me, are

waiting for a strong regulation of janitorial products and hope you

will remind your staff they need to include them in the 2010

Consumer Products regulation. The regulation of janitorial

products is a very important protection in our work.
Again, thank you for your commitment. 

Sincerely,

Heriberta Sandoval, 

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2009-09-23 11:28:23

No Duplicates.
Comment 15 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: Luis

Last Name: Cabrales

Email Address: luis@coalitionforcleananir.org

Phone Number: 12136301192

Affiliation:

Subject: 2009 Consumer Products Regulation Amendments

Comment:

Please see the attached comments on behalf of the following

organization:

COALITION FOR CLEAN AIR

CLEAN AIR NOW

SEIU-USWW

ASIAN COMMUNITIES FOR REPRODUCTIVE JUSTICE ENVIRONMENT CALIFORNIA

CENTER FOR PUBLIC ENVIRONMENTAL OVERSIGHT

BAY AREA HEALTHY 880 COMMUNITIES-SL

NATURAL RESOURCES DEFENSE COUNCIL

AMERICAN LUNG ASSOCIATION IN CALIFORNIA

ENVIRONMENT NOW

SIERRA CLUB CALIFORNIA

TRI-VALLEY CARES

WOMEN’S VOICES FOR THE EARTH

GREEN SCHOOLS INITIATIVE

SIERRA CLUB—ANGELES CHAPTER

EARTH DAY L.A.

REGIONAL ASTHMA MANAGEMENT AND PREVENTION/

COMMUNITY ACTION TO FIGHT ASTHMA

INSTITUTO DE EDUCACIÓN POPULAR DEL SUR DE CALIFORNIA

COMMUNITIES FOR A BETTER ENVIRONMENT

CALIFORNIA HEALTHY NAIL SALON COLLABORATIVE

TEENS TURNING GREEN

Attachment: www.arb.ca.gov/lists/cpmthd310/196-2009_carb_reg_comments_092409.pdf

Original File Name: 2009 CARB Reg Comments_092409.pdf 

Date and Time Comment Was Submitted: 2009-09-23 11:48:00

No Duplicates.
COALITION FOR CLEAN AIR 

CLEAN AIR NOW 

SEIU-USWW 

ASIAN COMMUNITIES FOR REPRODUCTIVE JUSTICE 

ENVIRONMENT CALIFORNIA 

CENTER FOR PUBLIC ENVIRONMENTAL OVERSIGHT 

BAY AREA HEALTHY 880 COMMUNITIES-SL 

NATURAL RESOURCES DEFENSE COUNCIL 

AMERICAN LUNG ASSOCIATION IN CALIFORNIA 

ENVIRONMENT NOW * SIERRA CLUB CALIFORNIA 

TRI-VALLEY CARES * WOMENíS VOICES FOR THE EARTH 

GREEN SCHOOLS INITIATIVE 

SIERRA CLUBóANGELES CHAPTER * EARTH DAY L.A. 

REGIONAL ASTHMA MANAGEMENT AND PREVENTION/ 

COMMUNITY ACTION TO FIGHT ASTHMA 

INSTITUTO DE EDUCACI”N POPULAR DEL SUR DE 

CALIFORNIA 

COMMUNITIES FOR A BETTER ENVIRONMENT 

CALIFORNIA HEALTHY NAIL SALON COLLABORATIVE 

TEENS TURNING GREEN 

September 24, 2009 

Mary Nichols 

Chairman 

California Air Resources Board 

1001 ìIî Street 

P.O. Box 2815 

Sacramento, CA 95812 

Via e-mail 

Re: 2009 Consumer Products Regulation Amendments 

Dear Chairman Nichols:

We, the cosigners, are writing to comment on the revised proposal for categories to be 

considered in the September 2009 Consumer Products Regulation Amendments. 

We applaud your agencyís efforts to reduce emissions of volatile organic compounds 

(VOCs) from consumer products and commend your staff for listening to CARB board 

membersí orders to help protect the health of California residents, consumers and 

workers. 
We would like to highlight the following items from the most recent draft proposal. 

MULTI-PURPOSE SOLVENT AND PAINT THINNER VOC LIMITS: 

Staff has proposed a reduction of Multi-purpose Solvent and Paint Thinner VOC 

limits in two parts: Tier 1: 30% VOC limit by 12/31/2010; Tier 2: 3% VOC limit by 

12/31/2013. Staff estimates that excluding SCAQMDís Rule 1143 reductions, this 

regulation will achieve a total of 14.7+ tons per day (tpd) VOC reductions by 2013. 

We are very hopeful about the estimated reductions from this regulation, but are 

concerned about the disparity with the SCAQMDís Rule 1143 implementation dates. 

We strongly encourage CARB to align the VOC limit implementation date for multipurpose solvents closer to Rule 1143, setting 2012 as the implementation timeline. 

Our main reasons for this request are as follows: 

1. The majority of the total volume of multi-purpose solvents and paint thinners 

is used for cleaning purposes, not thinning. 

2. We are concerned that, as a result, products labeled as paint thinners will be 

inappropriately being used as multi-purpose solvents. 

3. SCAQMD staff has conducted an extensive technology review of research on 

alternative products and found 164 that would meet the 3% VOC limit. These 

products are already available and 102 are certified under SCAQMDís 

Certified Clean-Air Solvents Program. 

We believe that by aligning the effective date for multi-purpose solvents closer to that 

of Rule 1143, CARB will reduce the health impacts associated with the misuse of 

these products, and will achieve VOC reductions one year earlier. 

PROPOSED NEW SUBSECTION 94509(U): 

We also want to express our strong support to the proposed new subsection 94509(u), 

which would prohibit perchloroethylene, methylene chloride and trichloroethylene on 

multi-purpose solvents and paint thinners. 

GLOBAL WARMING EMISSIONS FROM CONSUMER PRODUCTS: 

We are very supportive of staffís efforts to look at global warming emissions from 

consumer products. Many of these consumer products and their ingredients contribute 

directly and indirectly to the GHG emissions. Prohibiting chemical compounds with high 

Global Warming Potential (GWP) value is a great start. We want to also encourage your 

agency to consider addressing other products and their ingredients and make 

California the first state to officially take steps to reduce our Global Warming foot 

print from consumer products. 

PROPOSED EXEMPTION OF ARTISTíS SOLVENT/THINNER SOLD IN 

CONTAINERS OF 32 FL. OZ. OR LESS: 

We are concerned about staffís proposal to exempt artistís solvent/thinner sold in 

containers of up to 32 fl. oz. We feel this exemption is not necessary, and will 

continue to expose people to these dangerous chemicals. However, if staff thinks an 

exemption for this type of products is absolutely necessary, we suggest that it is a 

temporary exemption of small size paint thinners sold in containers of 8 fl. oz. or less. 
CONSUMER PRODUCTS REGULATION IN 2010: 

Staff mentioned there will be another regulation process for the Consumer Products 

category in 2010. Staff has not shared details about the regulation, but according to their 

estimates, this regulation may help the state achieve an additional 5-8 tons per day (tpd) 

of VOC emissions reductions. We are hopeful staff will also include the following 

pending regulations, some of which were ordered by the Board members in 2008. 

1. JANITORIAL PRODUCTS: 

During the June 2008 Board meeting, the Board instructed staff to regulate this 

category. Although staff has been working to compile data for possible VOC limits in 

cleaning products, and to allow for the peer review exposure scenarios reflecting the 

potential for increased use of certain toxic low vapor pressure solvents, it has been 

more than one year since the decision was made by the Board. We encourage you to 

direct staff to look at the information shared by the SCAQMD. CARB will be able to 

move forward with this regulation at a faster and less expensive manner. 

 

As you may have learned, SCAQMD researched possible VOC reductions in a broad 

category of janitorial cleaning products. The SCAQMDís Clean Air Certification 

Program has already tested more than 50 cleaners able to meet the 1% VOC limit, 

which are cost-competitive and do not contain the compounds under review at 

OEHHA. However, if staff is concerned that industry may reformulate using those 

toxic low vapor pressure solvents, we urge you to direct staff to prohibit them. 

Alternatively, consideration should be made to remove the exemption for low vapor 

pressure solvents. These solvents eventually evaporate and ultimately contribute to 

VOC emissions. 

 

2. METHYLENE CHLORIDE IN PAINT REMOVERS OR STRIPPERS: 

Staff has evaluated the products reported in the 2006 survey of Paint Removers and 

Strippers to reduce VOC emissions and ban the use of methylene chloride. Since 

1/1/2005, the VOC limit for these products has been 50% by weight. Methylene 

chloride, however, is the most common ingredient; it is used by more than 50% of 

reported products, with concentrations ranging between 17 and 93% by weight. 

CARB staff is evaluating several potential alternatives (benzyl alcohol, dibasic esters 

and dimethyl sulfoxide) to move forward with a safe ban of methylene chloride. We 

commend this work and are very hopeful about the possibility of regulating this 

chemical. 

3. DRY-CLEAN ONLY SPOT REMOVERS: 

Staff is evaluating the findings from its 2008 survey for the use of dry-clean only spot 

removers. Seven companies reported 48 products with VOC content ranging from 

less than 1% to 100%. Although CARB calculates 0.16 tpd of VOC emissions, the 

survey confirmed our concerns that Trichloroethylene was the most common VOC 

reported. CARB is evaluating the feasibility of reducing VOCs and TACs from 

formulations in these products. We hope staff will draft a proposal to remove the 

exemptions that prevent them from regulating dry cleaning only spot removers and 

include them in the 2010 Consumer Products rulemaking processes. 
4. NAIL COATINGS EXPOSURE ASSESSMENT: 

Staff is evaluating the feasibility of regulating xylenes, toluene, dibutyl phthalate and 

formaldehyde from nail coatings used in nail salons. CARB staff conducted several 

site visits to Bay Area nail salons for information about the amount and type of 

products used. Staff is currently performing emissions modeling and will analyze and 

summarize the results. Staff has not confirmed when they will be done with this 

assessment, but we are urging them to continue working on this important matter and 

include a regulation in the 2010 Consumer Products rulemaking processes. 

 

The actions suggested above will help CARB save much needed resources and move 

closer to achieving its 2007 SIP commitments. But most importantly, these actions are 

critical in the work and home environments, where exposure to emissions from products 

tends to be more than outdoors. We encourage you to not only choose the most 

environmentally friendly VOC limit but also one that is health protective and in line with 

the laudable goals put forward by the California Green Chemistry Initiative. 

Again, thank you for your commitment to regulate VOCs in consumer products. We are 

very hopeful about this regulationís potential to help protect the health of California 

residents, consumers and workers who use these products on a daily basis. 

We look forward to continue working with you on this important decision-making 

process. 

Sincerely, 

Luis R. Cabrales, 

Senior Campaign and Outreach Associate 

Coalition for Clean Air 

James J. Provenzano, C.Ph., 

President, 

Clean Air Now 

Mike Garcia, 

President 

SEIU-USWW 

Eveline Shen, 

Executive Director 

Asian Communities for Reproductive Justice 

Pamela King Palitz

Environmental Health Advocate and Staff Attorney

Environment California

Lenny Siegel, 

Executive Director 

Center for Public Environmental Oversight 
Wafaa Aborashed, 

Executive Director 

Bay Area Healthy 880 Communities-SL 

Adrian Martinez, 

Project Attorney 

Natural Resources Defense Council 

Bonnie Holmes-Gen, 

Senior Policy Director 

American Lung Association in California 

Mara Burstein, 

Air Program Manager 

Environment Now 

Bill Magavern, 

Director 

Sierra Club California 

Marylia Kelley, 

Executive Director 

Tri-Valley CAREs 

Erin Switalski, 

Acting Executive Director 

Womenís Voices for the Earth. 

Anne Kelsey-Lamb, 

Director 

Regional Asthma Management and Prevention and 

Community Action to Fight Asthma 

Deborah Moore, 

Executive Director 

Green Schools Initiative 

Jim Stewart, PhD, 

President 

Earth Day L.A. 

Co-chair, 

Sierra Club Angeles Chapter 

Global Warming, Energy & Air Quality Committee 

Raul Anorve, 

Executive Director 

Instituto De EducaciÛn Popular Del Sur De California 

Bahram Fazeli, 

Research & Policy Analyst 

Communities for a Better Environment 
Julia Liou, 

Coordinator 

California Healthy Nail Salon Collaborative 

Judi.Shils, 

Executive Director 

Teens Turning Green 
Comment 16 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First Name: Heidi

Last Name: McAuliffe

Email Address: Non-web submitted comment

Phone Number: 

Affiliation:

Subject: National Paint & Coating Association

Comment:

Please see attached. 

Attachment: www.arb.ca.gov/lists/cpmthd310/197-cpmthd0001.pdf

Original File Name: cpmthd0001.pdf 

Date and Time Comment Was Submitted: 2009-10-05 16:22:50

No Duplicates.



Comment 1 for Consumer Products Test Method 310 (cpmthd310). (At

Board Hearing)

First Name: Chet 

Last Name: Thompson

Email Address: Non-web submitted comment

Phone Number: 

Affiliation:

Subject: American Chemistry Council

Comment:

please see attached

Attachment: www.arb.ca.gov/lists/cpmthd310/198-chet.pdf

Original File Name: Chet.pdf 

Date and Time Comment Was Submitted: 2009-10-06 10:00:20

No Duplicates.


Comment 2 for Consumer Products Test Method 310 (cpmthd310). (At

Board Hearing)

First Name: Barry 

Last Name: Wallerstein

Email Address: Non-web submitted comment

Phone Number: 

Affiliation:

Subject: South Coast AQMD

Comment:

please see attached

Attachment: www.arb.ca.gov/lists/cpmthd310/199-barry.pdf

Original File Name: Barry.pdf 

Date and Time Comment Was Submitted: 2009-10-06 10:00:20

No Duplicates.