### 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”) 1 of the American Chemistry Council is pleased to submit the following comments on the California Air Resources Board’s (“CARB” or “Board”) p roposed modified text for Consumer Products Regulation and Test Method 310. SIG member companies would be significantly affected by this regulation and thus hav

e a n interest in the rule’s developm ent 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 aro matic 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 ar omatic definiti on 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 envir onmental issues affecting both the producers and users of those materials . Members of SIG include: The Dow Chemical Company, ExxonMobil Chemical Co rporation

, 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.