Comment 1 for Consumer Products Test Method 310 (cpmthd310) - 15-1.

First Name: Steve

Last Name: Bunting

Email Address: sbunting@nbfd.net

Phone Number: 

Affiliation: So Cal Fire Prevention Officers

Subject: Proposed Modified Regulatory Language (1/14/10)

Comment:

Title 17, CCR, section 94512(e): No objection to the changes.

Strongly agree with the addition of the Spanish text in subsection

2, A and B.

Title 17, CCR, section 94508(a): No objections to the changes to

the definitions.

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2010-01-14 14:46:55

No Duplicates.
Comment 2 for Consumer Products Test Method 310 (cpmthd310) - 15-1.

First Name: Leslie

Last Name: Berry

Email Address: Leslie_Berry@americanchemistry.com

Phone Number: 

Affiliation:

Subject: American Chemistry Council Comments

Comment:

American Chemistry Council's Solvents Industry Group Comments

Attachment: www.arb.ca.gov/lists/cpmthd310/203-sig___cp_15_daycomments_final.pdf

Original File Name: SIG _ CP 15 dayComments final.pdf 

Date and Time Comment Was Submitted: 2010-01-29 12:07:45

No Duplicates.
January 29, 2009

Via Electronic Mail

California Air Resources Board

1001 I Street

Sacramento, California 95814

Attn: Alexa Malik, Clerk of the Board

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

Re: 15-Day Notice of Public Availability of Modified Text for the Public 

Hearing to Consider Proposed Amendments to the California

Consumer Products Regulation

Dear Honorable Board Members:

The Solvents Industry Group (“SIG”) 1of the American Chemistry Council is 

pleased to submit the following comments on the California Air Resources Board’s 

(“CARB” or “Board”) proposed modified text for Consumer Products Regulation and Test 

Method 310. SIG member companies would be significantly affected by this regulation 

and thus have an interest in the rule’s development and implementation. The comments 

below relate only to the modified text in the 15-day notice.

After careful review of the modified text, the SIG cannot support the adoption of 

the proposed definition of aromatic compound. The proposed definition is inconsistent 

with the definition used in the Consumer Products Regulation to define what compounds 

are considered VOCs. As described, the proposed aromatic definition would incorrectly

classify aromatic compounds. SIG urges CARB to revise the proposed aromatic 

definition to the following:

“Aromatic Compound” means a carbon containing volatile compound 

whose predominant components contain one or more benzene or 

equivalent heterocyclic ring(s) and has an initial boiling point less than or 

equal to 216 C. “Aromatic Compound” does not include compounds 

excluded from the definition of Volatile Organic Compound (VOC) in this 

Section 94508(a).

 

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

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

that may impact the solvent industry. 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

Solvent Industry Group Panel Manager

Chemical Products and Technology Division
Comment 3 for Consumer Products Test Method 310 (cpmthd310) - 15-1.

First Name: Joseph

Last Name: Yost

Email Address: jyost@cspa.org

Phone Number: 202-833-7325

Affiliation: Consumer Specialty Products Association

Subject: 15-Day Notice - Modifications to Text of Proposed 2009 Amendments

Comment:

Attached, please find the Consumer Specialty Products Association’s

(CSPA’s) comments on the ARB’s 15-Day Notice issued pursuant to

Board Resolution 09-51, as approved at the public hearing held on

September 24, 2009. CSPA appreciates the opportunity to

participate in the ARB’s open and transparent public process to

develop the 2009 Amendments to California’s very comprehensive

Consumer Products Regulation.

Attachment: www.arb.ca.gov/lists/cpmthd310/204-cspa_comments_on_arb_15-day_notice_-

_modified_text_of_2009_amendments.pdf

Original File Name: CSPA Comments on ARB 15-Day Notice - Modified Text of 2009

Amendments.pdf

Date and Time Comment Was Submitted: 2010-01-29 12:24:05

No Duplicates.





Comment 4 for Consumer Products Test Method 310 (cpmthd310) - 15-1.

First Name: Heidi 

Last Name: McAuliffe

Email Address: hmcauliffe@paint.org

Phone Number: 

Affiliation: American Coatings Association

Subject: Comments on 15 Day Notice Consumer Products

Comment:

January 29, 2010

California Air Resources Board

1001 I Street

Sacramento, California 95814

Attn: Alexa Malik, Clerk of the Board

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

Subject: Comments to ARB’s 15 Day Notice of Modified Text to 2009

Amendments

Dear Members of the Air Resources Board:

The American Coatings Association appreciates the opportunity to

comment on the California Air Resources Board’s (ARB’s) 15-Day

Notice of Public Availability of Modified Text for the Public

Hearing to Consider Proposed Amendments to the California Consumer

Products Regulation. 

The American Coatings Association (ACA) 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. ACA

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. 

After reviewing the changes in the 15 Day Notice, the ACA has the

following comment.

The proposed definition of the aromatic compound (13) is in

conflict with the current definition for (94) LVP-VOC and should be

reconciled to the current regulatory definition.

 The current definition of LVP-VOC is as follows:

“LVP-VOC” means a chemical “compound” or “mixture” that contains

at least one carbon atom and meets one of the following:

(A) has a vapor pressure less than 0.1 mm Hg at 20°C, as

determined by ARB Method 310; or
(B) is a chemical “compound” with more than 12 atoms, or a

chemical “mixture” comprised solely of “compounds” with more than

12 carbon atoms, as verified by formulation data, and the vapor

pressure and boiling point are unknown; or

(C) is a chemical “compound” with a boiling point greater than

216°C, as determined by ARB Method 310; or

(D) is the weight percent of a chemical “mixture” that boils above

216°C, as determined by ARB Method 310.

For the purpose of the definition of LVP-VOC, chemical “compound”

means a molecule of definite chemical formula and isomeric

structure, and chemical “mixture” means a substance comprised of

two or more chemical “compounds.”

The current definition of aromatic compound is as follows:

“Aromatic Compound” means a carbon containing compound that

contains one or more benzene or equivalent heterocyclic rings and

has an initial boiling point less than or equal to 280oC. “Aromatic

Compound” does not include compounds excluded from the definition

of Volatile Organic Compound (VOC) in this Section 94508(a).

The two definitions are clearly in conflict with each other and

should be reconciled to the current regulatory definition.

We are aware that the National Aerosol Association (NAA) and the

Consumer Specialty Products Association (CSPA) has proposed

solutions for this inconsistency. ACA recognizes the importance of

the LVP-VOC exemptions and wants to make sure that the regulatory

language proposed in this rulemaking does not jeopardize this

concept. ACA supports reconciliation of this language in order to

ensure that the definition of “Aromatic compound” does not include

compounds defined as LVP-VOC. Both NAA and CSPA's proffered

solution will accomplish this.

ACA appreciates the opportunity to submit this comment. If you

have any questions, please do not hesitate to contact me.

Best regards,

Heidi K. McAuliffe, Esq.

Counsel, Government Affairs

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2010-01-29 16:11:47

No Duplicates.
Comment 5 for Consumer Products Test Method 310 (cpmthd310) - 15-1.

First Name: Michael S.

Last Name: Cooley

Email Address: Non-web submitted comment

Phone Number: 

Affiliation:

Subject: BARR

Comment:

please see attached.

Attachment: www.arb.ca.gov/lists/cpmthd310/208-cooley.pdf

Original File Name: Cooley.pdf 

Date and Time Comment Was Submitted: 2010-02-04 15:10:44

No Duplicates.


Comment 6 for Consumer Products Test Method 310 (cpmthd310) - 15-1.

First Name: Douglas

Last Name: Raymond

Email Address: djraymond@reg-resources.com

Phone Number: 

Affiliation:

Subject: National Aerosol Association

Comment:

please see attached

Attachment: www.arb.ca.gov/lists/cpmthd310/209-doug.pdf

Original File Name: Doug.pdf 

Date and Time Comment Was Submitted: 2010-03-02 15:41:15

No Duplicates.