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1 STATE OF MAINE 

2 BOARD OF ENVIRONMENTAL PROTECTION 

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IN RE : CHAPTER 152 : CONTROL OF 

7 VOLATILE ORGANIC COMPOUNDS 

8 FROM CONSUMER PRODUCTS 

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12 PRESIDING OFFICER: VIRGINIA PLUMMER, CHAIRWOMAN 

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This hearing was held pursuant to Notice at the 

15 Holiday Inn, Civic Center Drive, Augusta, Maine, 

16 on August 2, 2007, beginning at 9:00 a.m. 

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6 HEARING EXAMINER: Good morning, 

7 everyone, and we're going to do, again, an agenda 

8 a little differently today. We're going to start 

9 with a public hearing and then we will go into a 

10 discussion of the Androscoggin river appeals and 

11 then we'll have our regular consent agenda -- our 

12 regular agenda items. 

13 My name is Ginny Plummer of the Board of 

14 Environmental Protection, and we are holding a 

15 public hearing today on the proposed Department of 

16 Environmental Protection amendments to Chapter 

17 152, Control of Volatile Organic Compounds from 

18 Consumer Products. I will be the presiding 

19 officer for today's hearing and other members here 

20 today are to my far right Ernie Hilton from Starks 

21 and next to him is Nancy Anderson from Cumberland 

22 Foreside, Elizabeth Ehrenfeld from Falmouth, 

23 Richard Gould from Greenville and Don Guimond from 

24 Fort Kent, and then Board Member Sue Lessard from 

25 Hampden, Nancy Ziegler from South Portland and 

1) ORIGINAL 

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(This hearing was held before the Board 

of Environmental Protection, Holiday Inn, Civic 

Center Drive, Augusta, Maine, on August 2, 2007, 

beginning at 9:00 a.m.) 

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1 Matt Scott from Belgrade, and to my right is Peggy 

2 Bensinger, our assistant attorney general, and to 

3 my left is Cindy Bertocci, the executive analyst, 

4 and seated next to Matt is our administrative 

5 assistant, Terry Hanson. Our recorder today is 

6 Joanne Alley of Alley & Morrisette Recording 

7 Services. Also present are Jeff Crawford and 

8 Andrea Lani and Ron Severance of the Department 

9 staff. 

10 Today's hearing is being held pursuant to 38 

11 M.R.S .A., section 585, 585-A and Public Law 

12 Chapter 384, Section 14. In addition, because 

13 these amendments will be submitted as a revision 

14 of Maine's State Implementation Plan for Air 

15 Quality, today's hearing will be conducted 

16 pursuant to the requirements of Title 40, Part 51 

17 of the Code of Federal Regulations . Notice of 

18 today's hearing was published in the Kennebec 

19 Journal on July 2nd, 2007 and in the Kennebec 

20 Journal, Lewiston Daily Sun, Waterville Morning 

21 Sentinel, Portland Press Herald and Bangor Daily 

22 News on July 11, 2007. Notice of today's hearing 

23 was also sent to all persons on the Department's 

24 regulatory notice mailing list, all licensed air 

25 emission sources and to others who have expressed 

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1 interest in the rules that are the subject of 

2 today's hearing . The record for written comments 

3 shall remain open until 5 p .m. on August 13th, 

4 2007. All written testimony should be addressed 

5 to the Bureau of Air Quality and clearly marked 

6 for inclusion in the August 2nd, 2007 Chapter 152 

7 public hearing record. Today's hearing will be 

8 transcribed and made available to all Board 

9 members. Based on the complete record, the Board 

10 will vote to approve, deny or amend the proposed 

11 amendments at a regularly-scheduled Board 

12 meeting. Copies of the final staff recommendation 

13 will be available upon request before the rule is 

14 presented for adoption. An attendance sheet is 

15 presently circulating the room. Please indicate 

16 on the sheet if you wish to receive a copy of the 

17 draft final rules. Following adoption of these 

18 rules, the Department will prepare a formal 

19 submittal to the U.S . Environmental Protection 

20 Agency for inclusion in the State Implementation 

21 Plan. 

22 At this time I would ask all persons who 

23 plan to testify to please stand to be sworn in and 

24 raise your right hand. Do you affirm that the 

25 testimony you are about to give is the truth and 

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1 nothing but the truth? 1 institutional settings such as beauty shops, 

2 (Witnesses respond in affirmative). 2 schools and hospitals . Examples of the types of 

3 CHAIRWOMAN PLUMNIER: Thank you. Procedures 3 products affected include personal care products, 

4 call for presentations, first, by proponents, 4 household products, automotive after-market 

5 second, by opponents and, third, by other 5 products, adhesives, sealants, insecticides and 

6 interested parties neither for nor against . If 6 other miscellaneous products . VOC emissions from 

7 you plan to speak and have not already done so 7 these products result from evaporation of 

8 please sign in now on the appropriate speakers' 8 propellant and organic solids during use. 

9 sheet which I believe is next to the podium. 9 There are current regulations that do impact 

1o Following each presentation there will be an 10 consumer products . The federal regulation which 

11 opportunity for Members of the Board to direct 1 I has been in effect since 1998 covers 24 product 

12 questions through the chair. Copies of the 12 categories which is about 48 percent of the 

13 proposed rule are available also on the side table 13 national consumer product inventory and reduces 

14 and that's it . Are there any questions? We will 14 VOC emissions by 20 percent. The existing State 

15 hear testimony first from Andrea Lani of the 15 Chapter 152 was adopted in September of 2004 and 

16 Bureau of Air Quality. Good morning . 16 expands on the federal rule. It covers 45 

17 MS. LANI: Good morning, Chairman Plummer, 17 consumer product categories -- it covers 

18 Members of the Board. 18 approximately 80 different types of products 

19 MS. BERTOCCI: You'll have to bring that 19 within 45 consumer product categories and places 

20 perhaps a little closer to you. 20 more stringent voC limits than the federal rule. 

21 Ms. LANE Is that okay? I'm Andrea Lani, 21 The state rule -- the initial rule reduced VoC 

22 I'm with the Department of Environmental 22 emissions by approximately two percent a day -- 

23 Protection Bureau of Air Quality, Program Planning 23 two tons per day, I'm sorry. 

24 Division. I'm here today to discuss the 24 The proposed amendments increase the 

25 Department's proposed amendments to Chapter 152, 25 categories by approximately 20 and also add the 

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1 Control of Volatile Organic Compounds from 1 toxic limits that I mentioned earlier. These 

2 Consumer Products Regulation. 2 proposed amendments are based on the model rule 

3 VOCs or volatile organic compounds react with 3 developed by the Ozone Transport Commission which 

4 nitrogen oxides in the presence of sunlight to 4 covers the Northeast and Mid Atlantic States . 

5 form ozone. Breathing ozone can irritate the 5 Their rules are based on emission limits already 

6 respiratory system, reduce lung function, 6 in place in California. In the OTC Region, 

7 aggravate asthma, inflame and damage the lining of 7 Connecticut, Delaware, Maryland, Massachusetts, 

8 the lungs and aggravate chronic lung disease . 8 New Hampshire, New Jersey, New York, Rhode Island 

9 Children, the elderly and those with chronic 9 and Virginia are all currently in the process of 

10 respiratory problems are most at risk. Healthy 10 adopting similar regulations . In Maine consumer 

I1 individuals may also experience increased 11 products are responsible for approximately 11 tons 

12 respiratory symptoms when exposed to ozone while 12 of VOC emissions per day and the proposed 

13 engaged in physical exertion . The proposed 13 amendments will reduce those emissions by 

14 amendments establish emission limits for volatile 14 approximately two-tenths of one ton, and as far as 

15 organic compound content of approximately 20 15 compliance goes, the manufacturers are required to 

16 additional categories of consumer products, and 16 date or date code their products and submit a date 

17 you can see those in the table in the rule, and 17 code explanation to the Department so that we'll 

18 the proposed amendments also include limits on 18 know that the date -- that the products 

19 certain toxic compounds in some consumer 19 manufactured after the effective date meet the 

20 products . The amendments also modify the date 20 requirements. To make this requirement a little 

21 coding requirements to make record keeping and 21 bit less onerous, if manufacturers use a Julian 

22 recording less onerous for manufacturers . 22 date that's described in the rule, then they don't 

23 Consumer products include products sold to retail 23 have to send in their explanations . The 

24 customers along with products marketed by 24 manufacturers are responsible for developing and 

25 wholesale distributors for use in commercial or 25 distributing compliant products for sale at the 

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retail and wholesale level, and the reporting 

provisions require manufacturers to submit 

additional information if the Department requests 

it. They also have the option of submitting 

variances, innovative product exemptions or 

alternate control plans that have been issued by 

CRB or another state with a similar regulation 

subject to approval by DEP and the EPA, and in 

addition to compliance obligations by the 

manufacturers, retailers and distributors will be 

held accountable for stocking compliant products . 

Chapter 152 should be transparent to 

consumers. They should not notice any changes in 

product performance or quality and the cost 

increases of the additional product requirements 

should add up to less than 50 cents per customer 

per year in Maine, and many of the products with 

the proposed vOC limits are currently available in 

California and other states and they should be 

technologically feasible, and if the Board has any 

questions at this time, I'll try to answer them. 

CHAIRWOMAN PLUMMER: Any questions? Yes, 

Matt. 

MR. SCOTT: Andrea, a couple of questions . 

You mentioned 11 tons per day produced vOCs? 

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1 MS. LANI: Yes. 

2 MR. SCOTT: And that reduction number again 

3 would be what? 

4 MS. LANI: It would be two-tenths of a 

5 ton. It's pretty small when you think of it that 

6 way. 

7 MR. SCOTT: Okay. I just wondered how much 

8 of a reduction that would be. So it's two-tenths 

9 and the other question that I have is for the 

10 retailers or producers, I'm sure that they must 

11 have to understand or have a list of these 

12 products that would have to come under this rule? 

13 MS. LANI: Yes. The advantage of doing 

14 this at a regional level is that the distribution 

15 networks will kind of cover a lot of the states 

16 that have this rule in effect so that makes it 

17 easier for the products to come into the state. 

18 When we initially passed -- adopted the first 

19 version of Chapter 152 we sent a letter to any 

20 retailer in the state or distributor that might 

21 sell these type of products just to alert them to 

22 the rule being in effect, but if Massachusetts and 

23 New Hampshire and Connecticut all have the same 

24 rule, it's likely that the distribution network 

25 should cover the states and the retailers in all 

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1 likelihood won't have to do a lot of proactive 

2 effort to make sure their products are compliant. 

3 MR. SCOTT: Thank you. 

4 CHAIRWOMAN PLUMMER: Yes, Elizabeth. 

5 MS. EHRENFELD: A follow-up question to 

6 Matt's, so the actual limits for all these 

7 compounds are the same in the proposed legislation 

8 in all the different states? 

9 MS. LANM: Yeah, unless there are some 

lo states that have modified theirs that we're not 

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aware of, but that's the idea behind the model 

rule is to keep it consistent across the broad 

swath. 

MS . EHRENFELD: And the one we're looking 

at there haven't been changes? 

MS. LANI: We haven't changed anything in 

Maine from the model. 

MS. EHRENFELD: Thank you. 

CHAIRWOMAN PLUMMER: Other questions? Yes, 

Sue. 

MS. LESSARD: You mentioned that there are 

a number of other states that currently were 

considering this? Have these all been adopted in 

those states or are they -- what ones are they 

adopted in and what ones are they not? 

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1 MS. LANI: Well, they're in the process in 

2 all of those states, and I was just talking to my 

3 colleague from the Consumer Products Commission 

4 and he mentioned that -- he might have more 

5 details but some of them have adopted. Every 

6 state has a different process . Some have to go 

through legislation after they've gone through 

their rulemaking process . New Jersey has just 

started theirs. Connecticut has not quite passed 

theirs yet. I believe Massachusetts has adopted 

theirs. The effective date is January I st, 2009 

so there's a year and a half before -- almost a 

year and a half before the effective date to give 

those other states time to get theirs adopted. 

MS. LESSARD: But at this point -- 

MS. LANI: At this point some of them have 

adopted and some haven't . The information isn't 

completely clear on that. 

CHAIRWOMAN PLUMMER: Yes, Matt. 

MR. SCOTT: So the bottom line then, 

Andrea, we, the consumers, will -- the only change 

we might see is the cost of the product then? 

MS. LANI: Potentially, yes. 

MR. SCOTT: Which might be a small increase 

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1 end result would be? 

2 MS. LANI: Right, there shouldn't be any 

3 different in the effectiveness of the products or 

4 anything that you would notice unless you pay 

5 attention to the date code labels : 

6 MR. SCOTT: All right. 

7 CHAIRWOMAN PLUMMER: Other questions? 

8 MR. SCOTT: That's very good. Thank you. 

9 CHAIRWOMAN PLUMMER: I just have one, and I 

10 think you answered it before but I can't remember 

11 and it's agricultural use. Could you explain -- 

12 it's on the first page 043 of the packet. 

13 MR. LANI: Yup. 

14 CHAIRWOMAN PLUMMER: Agricultural use does 

15 not include the sale or use of pesticides in 

16 properly labeled packages . So those are included 

17 or -- 

18 MS. LANI: Agricultural use pesticides 

19 would be exempt. It would just be a home use, 

20 insect fogger or something like that. 

21 CHAIRWOMAN PLUMMER: Okay, and is that done 

22 somewhere else? 

23 MS. LANI: Yes. Agriculture is under a 

24 different -- in Maine it's the Board of Pesticide 

25 Control. Federally there's another . 

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for agricultural use and that's where the 

agriculture comes into effect, and those items 

that require structural pest control license which 

would be if you were a company that eliminated 

termites or something like that and then other 

restricted materials . So it's less in terms of an 

agricultural use than a home use, a small 

container size or household product type. So 

that's where the agriculture comes into play as an 

exemption. 

MR. SCOTT: Since we have a Pesticides 

Control Board, all of that would come under their 

jurisdiction then? 

MS. LANI: Yup, and none of that has 

changed in this go-around but the first time we 

went through we worked with the Board of Pesticide 

Control to make sure that none of this conflicted 

with anything that they do. 

MR. SCOTT: Thank you for explaining that. 

That's good. 

CHAIRWOMAN PLUMMER: Ernie. 

MR. HILTON: So this rule -- did California 

write the rule and that became the model rule? 

MS. LANI: California's rules, the way I 

understand it, I think it was sort of more 

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1 CHAIRWOMAN PLUMMER: Okay. Now I 

2 remember. You told us that, yup. 

3 MS. LANI: So it's just the things that we 

4 use in the home and that's only in terms of the 

5 VOC content of those products not anything else 

6 that's related to how those operate . 

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MR. SCOTT: That raises another question, 

Ginny. 

CHAIRWOMAN PLUMMER: Okay. 

MR. SCOTT: Under the federal regulations 

we have what we called the FIFA Act which is the 

Federal Insecticide and Fungicide Act. So all of 

those products then would not -- would be exempt 

under this rule I assume if all of those come 

under the agricultural activities? 

MS. LANI: Not necessarily. 

MR. SCOTT: Okay. 

MS. LANI: I think if you look under -- let 

me find the page, if you don't mind taking a 

second. There are a lot of pages and 

definitions . If you g6 to 59 of the Board packet 

-- the previous Board packet that this was in, it 

has a definition for insecticide and it means a 

pesticide product that's designed for use against 

insects or other arthropods but existing products 

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1 piecemeal, and California has different area's of 

2 control districts that pass rules at different 

3 times, but the OTC took the limits that California 

4 has and used those in the basis for writing the 

5 model rule and then they also had stakeholder 

6 groups to help implement -- to figure out how 

7 those will work out in the Northeast but it's not 

8 an exact copy of what California has . 

9 MR. HILTON: So California's sensibilities 

1 o about agriculture versus consumer really provided 

11 the structure for this rule that we're seeing here 

12 today probably? 

13 MS. LANI: Probably. 

14 MR. HILTON: So out of the 11 tons a day 

15 of vOC which I guess is that all consumer or is 

16 that -- 

17 MS. LANI: That's just consumer products, 

18 just these product categories that are in this 

19 rule . 

20 MR. HILTON: And if we were to include all 

21 of the agriculture use, do you have any idea how 

22 many more tons a day that would be? It's seasonal 

23 I'm sure. 

24 MS. LANI: I Can't speak to that rate, and 

25 because their products are applied differently, 

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1 they may have -- because they're not pressurized. 

2 Part of the vOC may be due to propellant and 

3 that's something that may not come into play for 

4 agriculture on a large scale. 

5 MR. HILTON: I'm really kind of surprised 

6 that they aren't able to reduce the vOCs 

7 substantially more. They did it with paint. 

8 Ms. LANI: Right. Well, the first rule we 

9 did was two tons so this is an additional 10 

1o percent of that. 

11 MR. HILTON: Oh, I see. 

12 MS. LANI: Or about. We have about 25 

13 percent more categories and about 10 percent more 

14 reductions. So we started with the low hanging 

15 fruit, if you will, and we're reaching a little 

16 higher up the tree now. 

17 MR. HILTON: We're glad you're over there. 

18 CHAIRWOMAN PLUMMER: And Cindy. 

19 MS. BERTOCCI: I was just looking at the 

20 definition of consumer product on page 2 of the 

21 rule and the last sentence that's added regarding 

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1 CHAIRWOMAN PLUMMER: Make sure you speak 

2 up. 

3 MS. LANI: I'm sorry. There's also an OTC 

4 model rule that applies specifically to adhesives 

5 and may have some interplay with this . I'll look 

6 into that. 

7 CHAIRWOMAN PLUMMER: Okay. Other 

8 questions? I'm just so impressed that on page 16 

9 there's so many hair products . I've never heard 

10 of half of these. Anyway, okay, if there are no 

11 other questions, thank you very much and we have a 

12 speaker in support -- oh, neither support or 

13 opposition, Joe Yost, and Consumer Specialty . 

14 Products Association . 

15 MR. YOST: Yes, ma'am, that's correct. 

16 Thank you, Chairwoman Plummer, and other 

17 distinguished Members of the Board. My name is 

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Joe Yost. I'm with the Consumer Specialty 

Products Association or CSPA, and in general CSPA 

represents a broad range of companies, 260 

companies, that manufacture, distribute, formulate 

and sell many different types of consumer 

products, also products that are sold in 

institutions and in commercial facilities . 

In summary, the current regulation in Maine 

22 aerosol adhesives, and my question is that the 

23 rule as a whole seems to really be focused on the 

24 homeowner and institutions that I'm assuming use 

25 fairly small quantities of these products but in 

I 1 this one we've got industrial uses as well. So 

' 2 adhesives I'm assuming are maybe used in large 

3 enough quantities that you really wanted to pull 

4 in the bigger industrial uses on adhesives or can 

5 you explain kind of why it's broader for that 

6 category than just the consumer? 

7 MS. LANI: I think if you also turn to the 

8 page 6 of the rule or 48 of the Board packet it 

9 has a definition for adhesive and it still has 

lo limitations on the quantities that are -- that are 

11 subjected to the limits . 

12 MS. BERTOCCI: Okay. 

13 MS. LANI: So I'm not 100 percent sure why 

14 they added the aerosol adhesives used in 

15 commercial/industrial uses to that but there's 

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,16 still a limitation on those products -- wait, no, 

17 those are minimums, aren't they? I'm sorry, I 

18 should be more familiar with that. I can find out 

19 the answer to that question and get back to you. 

20 I'm not sure why they added industrial uses for 

21 aerosol adhesives . 

22 MS. BERTOCCI: Okay, thank you. 

23 MS. LANI: Because there is also an OTC 

24 adhesive rule that we haven't decided if we're 

25 going to pursue as well. 

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and the proposed regulation directly affects about 

two-thirds -- two-thirds of the standards set 

under the current and proposed regulation have a 

4 direct effect on CSPA member company products . 

5 Before I begin, I'd just like to maybe clarify a 

6 couple points that were raised in the discussion. 

7 At this stage no state has adopted a final 

8 regulation that incorporates the provisions of the 

9 revised OTC model rule. That's the revisions that 

10 you all are considering here that the Department 

11 is proposing . Massachusetts started a rulemaking 

12 in early January, Maryland started rulemaking in 

13 April and Maine is one -- is at the forefront of 

14 this issue by starting this rulernaking right now. 

15 So the other states are sort of following Maine's 

16 lead but Maine in no way is behind any other 

17 state, in fact, Maine is at the forefront of the 

18 effort to consider revisions to the Ozone 

19 Transport Commission's volatile rule. Secondly, 

20 regarding FIFA regulated products, as was 

21 correctly stated, many FIFA regulated products are 

22 consumer products, they are subject to regulation 

23 by both the U.S. Environmental Protection Agency 

24 and the Maine Board of Pesticide Control, and 

25 actually as true in Maine and any other state 

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1 quite truthfully, the largest number of products 

2 registered are consumer products . So not all 

3 those products are directly subjected to this rule 

4 but clearly many consumer products are subject, 

5 actually mostly insecticides and some herbicides. 

6 And finally in terms of CRB, California Resources 

7 Board, in terms of regulation of consumer 

8 products, CRB regulates consumer products on a 

9 statewide basis. Other types of products such as 

10 paint, for instance, may be regulated on a 

11 district by district, there are 35 air districts 

12 in California, but as pertains to consumer 

13 products, they all are subject to one statewide 

14 regulation by statute and that regulation is 

15 administered by the California Resources Board, 

16 and the current OTC model or revised OTC model are 

17 premised on the California regulations. They took 

18 the vOC limits in California but they scaled back 

19 some of the administrative provisions because 

2o quite truthfully CRB has a very large staff that 

21 deals with these regulations . There are 67 

22 full-time equivalent staffers that administer and 

23 enforce consumer product regulations in 

24 California. It's mind boggling . No other state 

25 has that level of commitment in terms of personnel 

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1 nationwide distribution of products untenable, but 

' 2 CSPA also represents a number of small companies, 

3 companies that manufacture on a regional basis. 

4 We don't represent any Maine only companies but 

5 there are a number of those companies that may be 

6 subject to this regulation so I think that the 

7 Department's proposal to establish a January 1, 

8 2009 effective date is quite reasonable. So it 

9 would allow these regional companies that may not 

10 be subject to this regulation now in California a 

11 sufficient amount of time to reformulate their 

12 products to comply with these very tough 

13 standards. 

14 If I may start the comments to say that I 

15 think as a threshold matter CSPA would urge the 

16 Board and the Department to consider a second and 

17 possible more efficient option of working with the 

18 U.S . Environmental Protection Agency and other 

19 states as EPA revises the current national 

20 consumer products rule, the rule that Ms. Lani 

21 explained was in effect or has been in effect 

22 since 1998. EPA is currently in the process of 

23 revising this rule. They are revising it in a way 

24 that is consistent with what the Board is 

25 currently proposing, this revised OTC model, so 

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or financial resources, but California also has 

the most significant challenges in dealing with 

air quality so that's probably quite reasonable. 

MR. HILTON: And that is just consumer 

products? 

MR. YOST: Yes, sir, consumer products --

let me rephrase that, consumer products and 

architectural coatings . California groups the two 

and that was -- that's not my estimate, that's a 

report that the Air Resources Board provided to 

the legislature. So, again, for the two, consumer 

products and architectural coatings, 67 FrES so 

it's understandable that the OTC model would scale 

back some of those administrative requirements in 

California but, again, the vOC limits are very 

similar, and as I mentioned, CsPA represents a 

wide range of companies . Many of our companies 

market products on a nationwide basis. So 

uniformity of regulation is of paramount 

importance, and while these standards are very 

tough, make no mistake about they are very 

stringent technology forcing standards, we would 

rather have one uniform set of standards to deal 

with than a patchwork of potentially differing 

state regulations because that would make the 

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that Maine would benefit from the reduction in 

vOCs that the Board -- excuse me, that the 

Department is proposing but this would save a 

considerable amount of administrative effort and 

expense for Maine if it were to rely on a national 

rule as opposed to a state specific rule, and from 

our perspective, again, the uniform national 

standards and the uniform interpretation of 

definitions and enforcement provisions is of 

paramount importance. As a practical matter, even 

slight differences between state regulations could 

potentially make these vOC limits unworkable. In 

the alternative, if the Board decides to go 

forward with the proposed amendments that the 

Department has put forward, we would like to 

suggest that in addition to what is before you 

that the Board consider revising the definition of 

volatile organic compound or vOC in Maine so that 

it is -- it incorporates the definition put forth 

by the U.S . Environmental Protection Agency. 

Currently the Maine definition is similar but it's , 

not entirely consistent and this definition of vOC ', 

is central to ensuring uniform interpretation and 

enforcement of this regulation. Other states such 

as New Hampshire and Pennsylvania make express 

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1 reference and incorporate the EPA definition. 

2 It's a very straightforward way to do it and while 

3 I say Maine's definition is relatively consistent, 

4 it lists a number of chemical compounds that have 

5 negligible photoreactive impact and exempts those 

6 but as EPA goes forward and occasionally changes 

7 its definition, Maine would have to change its 

8 definition as well to be consistent which is an 

9 additional administrative step; whereas, if Maine 

10 were to expressly incorporate the EPS definition, 

11 it would be much more efficient and eliminate this 

12 additional step. 

13 Second, as I mentioned before, we think that 

14 if the Board goes forward, the January 1, 2009 

15 effective date is essential and, again, it's 

16 particularly essential for small companies and 

17 specifically for Maine only companies. Although 

18 we don't represent them, as a matter of 

19 fundamental fairness we think it's important that 

20 those companies not be adversely impacted by a 

21 regulation that may cause them to reformulate 

22 their products . 

23 Third, CSPA supports the current provisions 

24 in the regulation that provide F1FA regulated 

25 products one additional year to comply with vOC 

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1 request that the final rule be revised to state 

2 that this -- the FIFA regulated products are 

3 subject to the voC limits and other provisions to, 

4 quote, one year after the date specified in the 

5 Table of Standards . This is language straight out 

6 of the OTC model and again provides necessary 

7 flexibility. 

8 Fourth, CSPA does not support adoption of 

9 the proposed restriction on certain chlorinated --

10 use of certain chlorinated compounds in electrical 

11 cleaner . Specifically perchloroethylene and 

12 methylene chloride are sometimes used by 

13 manufacturers to formulate nonflammable products . 

114 There is a definition for a product called 

15 energized electrical cleaner but -- and this 

16 specific narrow sub-category of products are 

17 exempted from the vOC limit for electrical cleaner 

18 but the problem is while energized electrical 

19 cleaner are supposed to be labeled in a certain 

20 way that clearly states that they are to be used 

21 on energized surfaces and not used on automobiles, 

22 et cetera, the practical realities are such that 

23 not everybody follows the manufacturer's advice. 

24 Manufacturers always say read the label and follow 

25 the instructions but you and I know that sometimes 

Page 26 

1 limits and other related enforcement provisions. 

2 This provision is in Maine's rule, it's also in 

3 the federal rule, it's in California's rule and 

4 it's in every other state rule that deals with 

5 consumer product regulation, and it's reasonable 

6 because there are two levels of review that these 

7 products have to go through if they reformulate 

8 products. On the one hand they must receive 

9 approval from the U.S . Environmental Protection 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

Agency and on the other hand in Maine they must 

receive approval from the Maine Board of Pesticide 

Control. This is time consiuning. We, thus, 

support the retention of this and, furthermore, we 

would suggest that there is a technical error 

though and I have other technical errors but I 

won't be so descriptive. We will file written 

comments and I will detail those, but I'll be very 

brief for the Board. Currently on page 27 of the 

revised rule, the new section 3-E makes explicit 

reference to May 1 st, 2006. That was the one year 

additional time to comply when this rule was first 

adopted. The rule initially took effect May 1, 

2005. Unfortunately by locking it into that 2006 

deadline, it undercuts and undermines the intended 

purpose of providing an additional rule. We would 

20 

21 

22 

23 

24 

25 

Page 28 

1 people don't always do that and an electrical 

2 cleaner versus an energized electrical cleaner may 

3 not be immediately discernible to an average 

4 citizen, and it's quite possible that somebody may 

5 pick up an electrical cleaner that is not 

6 formulated to be nonflammable and use it on an 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

energized electrical surface or a surface with 

energized electricity and this could cause a 

health and safety issue; thus, we would suggest 

that the rule be revised to remove the restriction 

on electrical cleaner . There are six other 

product categories that are subject to 

restrictions on the use of chlorinated solvents . 

We don't object to those but, again, for health 

and safety reasons we think the electrical cleaner 

issue needs additional work and we would like to 

work with the Department to further express our 

concerns. Again, there are several different 

technical issues . I mentioned one. If I may 

mention one other that I think is fairly 

significant, the definition for existing product, 

the term existing product, this is found at page 3 

of the new section 2-A, Subsection 20. The date 

referred to is September 1, 2004. That's when the 

current rule was approved as a final regulation 

20 

21 

22 

23 

24 

25 

Page 25 - Page 28 
CondenseIt! T"` 

I Page 29 

1 but that's not when the current rule -- the 

2 effective date of the current rule of standards 

3 took effect. Those standards took effect May 1, 

4 2005 . So this is an error. It's a minor 

5 technical error but it could have significant 

6 consequence. Instead of identifying a specific 

7 date as is done here, again this is the wrong 

8 date, it would be better to follow what the OTC 

9 model has done and state that it should take 

lo effect as of the date of the applicable standards, 

11 the table of standards. As you'll see in the rule 

12 before the proposed rule, there are two columns, 

13 one that says May 1, 2005, a second that says 

14 January 1, 2009. The term existing product is 

15 important and it really needs to have that 

16 flexibility so that you know which effective date 

17 that existing product is held to, and by making 

18 this change it's to say that, again, the 

19 applicable date in the table of standards resolves 

20 the problem very nicely. 

21 All right, again, in conclusion, CSPA will 

22 be submitting detailed written comments to 

23 identify several technical issues that need to be 

24 resolved. In summary, Maine -- when the 

25 Department and the Board considered the current 

Page 30 

rule, CSPA worked very closely with the Department 

and other stakeholders . In summary, we felt that 

Maine DEP was very reasonable in the way that they 

adopted a very comprehensive and very technology 

forcing regulation back in 2004, and we look 

forward to working with the Department and other 

stakeholders as it goes forward and consider 

whether to adopt revisions to this existing rule. 

I'd like to thank you very much for this 

opportunity to present our concerns and, again, we 

look forward to working cooperatively with your 

Department as it goes forward on this very 

important issue. I'd be happy to answer any 

questions . 

CHAIRWOMAN PLUMMER: Thank you. 

Questions? Ernie. 

MR. HILTON: To what degree -- you seem to 

have enunciated a number of areas in which the 

I1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

Page 

existing product, for instance . As pertains to 

the vOC limits, the Department is dead on 

consistent with the OTC model. In fact, I think 

the Department did a rather extraordinary job of 

ensuring consistency which is one of the real 

benefits of the Ozone Transport Commission. I 

mean, it provides a forum for Maine and other 

states to work on a common problem ozone transport 

and to do it in a way that is consistent and very 

thorough, and so they're minor technical errors 

that I think can be corrected. This is a very 

comprehensive amendment so it's not altogether 

surprising that there may be a few minor errors, 

and I guess it goes to the adage that many eyes 

make the job easier or many hands make work easy. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 We have a lot of people reviewing this, they may 

17 identify technical errors and we will work with 

18 the Department to bring these issues to their 

19 attention. 

20 MR. HILTON: Were you involved or your 

21 organization involved in the OTC's drafting of 

22 these rules? 

23 MR. YOST: As a stakeholder, yes. The OTC 

24 had a very open and transparent process to develop 

25 the model rule. I know the Maine Department of 

19 Department's proposed rule deviates from the model 

20 rule. 

21 MR. YOST: Yes. 

22 MR. HILTON: In terms of the date issues 

23 and some of these other issues? 

24 MR. YOST: Yes, that was in terms of just 

25 specifically with the definition of the term 

1 

, 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

31 

Page 32 

Environmental Protection was a very active member 

within the Ozone Transport Commission's consumer 

products work group as they developed these rules, 

and fortunately we were able to express our 

concerns throughout the development of this . 

MR. HILTON: And, yet, there are a number 

of ways in which you want us to deviate from those 

in adhering more closely to the EPA proposals or 

prospects? 

MR. YOST: Well, Mr. Hilton, actually 

within the model rule there are -- well, let's 

address the first issue, the definition of vOCs. 

The OTC model rule has three options, to either 

adopt the EPA definition, to have a state specific 

definition or have California's definition. 

MR. HILTON: I see. 

MR. YOST: I would submit to you the 

California definition is really a non-starter in 

that they, again, have a very different set of 

issues and they are a different state, but in 

terms of option one and two, we would hardly 

suggest that the Department consider option one 

and following the EPA definition. As pertains to 

the energized electrical cleaner versus electrical 

cleaner issue we expressed our concerns at the 

Page 29 - Page 32 
CondenseIt! ' 

Page 33 

I OTC, and they said that -- first of all, the OTC 

2 deals with ozone. They put this other issue --

3 the restriction on chlorinated solvents use as a 

4 toxic air contaminant issue. We agree that these 

5 chemical compounds, the use of those compounds, 

6 should be restricted but in certain limited 

7 instances there are legitimate reasons why you 

8 might want to have that option to use them and 

9 we're just suggesting with this one limited case 

10 with electrical cleaner that the Department might 

11 want to consider that. Aside from that, our goal 

12 is to ensure consistency and I go from state to 

13 state in this and that's why when I was citing off , 

14 what these other states were doing, I had the 

15 opportunity to go and testify at their hearings or 

16 submit written comments. We want to make sure 

17 that states follow this OTC model. It's a tough 

18 model, we don't like everything in it, but now 

19 that it's a done deal uniformity is far more 

20 important than trying to address some of the 

21 problems in this model. 

22 MR. HILTON: I see. 

23 CHAIRWOMAN PLUMMER: Other questions? 

24 Elizabeth. 

25 MS. EHRENFELD: I wanted to go over a 

I little bit your suggestions for the changes 

2 definition of volatile organic compound. 

3 that in the -- 

Page 34 

in the 

Where is 

4 MR. YOST: Unfortunately I copied the 

5 definition but I didn't put the citation here, 1 

6 apologize, but for Maine it lists a number of the 

7 chemical compounds that EPA exempts such as 

8 acetone, methane, ethane -- oh, let me rephrase 

9 that. Thank you very much. 

10 CHAIRWOMAN PLUMMER: The only definition I 

1 I could find was the high volatility organic 

12 compound. 

13 MR. YOST: It's defined in a separate 

14 section of the Maine regulation. 

15 CHAIRWOMAN PLUMMER: Andrea, could you --

16 MS . LANI: I think Joe was just about to 

17 address this. It's in Chapter 100 definitions and 

18 we didn't include it in there because, like he 

19 mentioned, it changes frequently. 

20 MS. EHRENFELD: So it's not part of this 

21 rule? 

22 MS . LANI: It's not in this rule . If we 

23 have a definition in Chapter 100 we usually don't 

24 include those in the specific rules unless there's 

25 some change and I don't have that. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

Page 35 

MS. ANDERSON: So this isn't before us at 

this point. It's not part of the regulations that 

are being addressed? 

MS. LANI: We could potentially define it 

differently in this rule from how we have it in 

Chapter 100. 

MR. YOST: And, again, the way it's defined 

currently in this general definition section is 

largely consistent with EPA. It's just not quite 

consistent and other states that have addressed 

this issue have resolved that problem by expressly 

referencing EPA definition. It's a matter of 

administrative efficiency really. 

MR. HILTON: Doesn't that create a 

consistency problem though across state lines for 

your manufacturers? I mean, they're manufacturing 

to EPA standards here and manufacturing to a local 

standard in California and -- 

14 

15 

16 

17 

18 

19 MR. YOST: Actually, Mr. Hilton, 

20 fortunately in California it's not local, it's 

21 statewide which is a big plus, believe me. If it 

22 were local, we'd be out of business in California 

23 but by and large most states are similar to EPA. 

24 For instance, there may be one or two compounds 

25 that EPA exempts that may not be exempt in Maine, 

Page 36 

1 for instance . I'm thinking t butyl acetate I 

2 believe . There may be another but that's the 

3 first example that pops into my mind, and I think 

4 the intent when this definition -- and I'm just 

5 guessing but it seems obvious by reading the 

6 definition, the intent was to be relatively 

7 consistent with the EPA definition but EPA's 

definition has apparently changed since this 

definition was put in place in Maine a number of 

years ago. I'm not a Maine lawyer so I don't know 

exactly when this regulation was put in place but 

I'm just suggesting this is an option for the 

Board to consider. Since you're working on a 

consumer products regulation that is directly 

relevant to the definition of vocs, I'm just 

raising this for an option that you may want to 

address . 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 CHAIRWOMAN PLUMMER: And in your written 

19 comments you can address that more specifically 

20 

21 

22 

23 

24 

25 

with the citation to Maine. 

MR. YOST: Yes, Ms. Plummer, I'll make sure 

I do that. 

CHAIRWOMAN PLUMMER: That will help us. 

MR. YOST: Yes, ma'am. Thank you. 

CHAIRWOMAN PLUMMER: Any other questions? 

Page 33 - Page 36 
CondenseIt! Tm 

Page 37 

1 Thank you very much. 

2 MR. YOST: Thank you. 

3 CHAIRWOMAN PLUMMER: Are there any others 

4 that wish to speak at this time? Seeing none, the 

5 hearing is closed. 

6 (Whereupon, the above-named hearing was concluded 

7 at 9:50 a.m.) 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

Page 38 

1 CERTIFICATE 

2 

3 1, Joanne P. Alley, a Notary Public in and 

4 for the State of Maine, hereby certify that on the 

5 2nd day of August, 2007, personally appeared 

6 before me the within-named witnesses who were 

7 sworn to testify to the truth, the whole truth, 

8 and nothing but the truth in the aforementioned 

9 cause of action and that the foregoing is a true 

10 and accurate record as taken by me by means of 

11 computer-aided machine shorthand. 

12 

13 1 further certify that I am a disinterested 

14 person in the event or outcome of the 

15 aforementioned cause of action . 

16 

17 IN WITNESS HEREOF, I have hereunto set my 

18 hand this 1 da of September, 2007. 

19 

20 

21 oar e P. Alley 

22 C rt Reporter/Notary Pubk/ 

23 

24 My commission expires : July 18, 2008 

25 

Page 37 - Page 38 
-0- 

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28 :24 29:3,13,14 

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35 :6 

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16:14 

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l4th [il 38:18 

152 [71 1 :7 2 :17 4:6 5:25 

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2006 [21 26:20,23 

2007 [8l 1 :16 2:3 3:19,22 

4:4,6 38 :5,18 

2008 [11 38 :24 

2009 [4] 12 :11 23:8 25 :14 

29:14 

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260 Ill 19:20 

27 Ill 26:18 

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acetone Ill 34:8 

Act [2] 14:11,12 

action [21 38:9,15 

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activities [i] 14:15 

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adhesive [21 18 :9,24 

adhesives pi 7:5 17 :22 

18:2,4,14,21 19:4 

administer [i] 21 :22 

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21 :19 22 :14 24:4 25:9 

35:13 

adopt [21 30:8 32 :14 

adopted [Ill 7:15 10:18 

11 :23,25 12 :5,10,14,17 

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adopting [il 8:10 

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27:8 

advantage [i] 10:13 

adversely [1] 25:20 

advice [1] 27:23 

aerosol [3] 17:22 18:14 

18:21 

affected[l] 7:3 

affects [ii 20:1 

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' 38:8,15 

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28:14,18 29:7,18,21 30:10 

32:19 35:7 

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23:18 24:20 26:10 

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21 :11 22:3,10 33:4 

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3:13 4:11 5:25 6 :14,18,20 

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apologize [1l 34 :6 

appeals[l] 2:10 

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19 :19 

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22 :12 

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15:22 16 :1,3,8 21 :6,12,15 

21 :17,18,24 22:1,8,15 

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23 :10 32 :18 35:18,20,22 

California's [41 15 :24 

16 :9 26:3 32 :15 

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case [1] 33:9 

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7:17,19,25 16 :18 17 :13 

28:12 

category Ill 18:6 

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central [il 24:23 

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27:19 33 :6 

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38 :1 

certify [21 38 :4,13 

cetera [1] 27:22 

chairp] 5:12 

Chairman [il 5:17 

Chairwoman [2s] 1 :12 

5:3 9:22 11 :4,19 12 :19 

13 :7,9,14,21 14:1,9 15:21 

17:18 19:1,7,16 30:15 

33:23 34:10,15 36:18,23 

36:25 37:3 

Ichallenges [1l 22 :2 

change [41 12 :21 25 :7 

29 :18 34:25 

changed [31 11 :16 15 :15 

36 :8 

changes [51 9:13 11 :15 

25:6 34:1,19 

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3:12 4:6 5:25 7:15 9:12 

10:19 34:17,23 35:6 

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34:7 

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I~ chloride [il 27:12 

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28:13 33:3 

chronic [21 6 :8,9 

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circulating Ill 4:15 

citation [2] 34:5 36:20 

citing Ill 33:13 

citizen [il 28 :4 

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clarify [il 20:5 

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27:19 28:2,2,5,11,15 

32:24,25 33:10 

clear [i] 12 :18 

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closely [zl 30:1 32:8 

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colleague [1l 12 :3 

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Index Page 1 
CondenseIt! ' comments - forcing 

comments [6] 4:2 23 :14 contaminant [i) 33 :4 Department's [4] 3:23 efficient [2] 23 :17 25 :11 exemptions [1] 9:5 

26:17 29:22 33 :16 36 :19 content [2] 6:15 14 :5 5:25 23 :7 30 :19 effort [3] 11 :2 20 :18 24:4 exempts [3] 25 :5 34:7 

commercial [2] 6:25 control [ill 1 :7 2:17 6:1 described [i 1 8:22 Ehrenfeld [61 2:22 11 :5 35 :25 

19:24 9:6 13 :25 15:3,12,17 16 :2 descriptive [11 26:16 11 :14,18 33:25 34:20 exertion [1] 6 :13 

commercial/industrial 20:24 26:12 designed [i] 14:24 either [i) 32:13 existing [s) 7:14 14 :25 

[i) )8:15 cooperatively [1] 30:1) detail [1] 26 :17 elderly [11 6:9 28:21,22 29:14,17 30:8 

commission [4] 8:3 12 :3 copied [i] 34:4 detailed [1] 29:22 electrical [13] 27:10,15 31:1 

3] :6 38:24 

' 

Copies[2] 4 :]2 5:12 details [i] 12:5 27:]7,18 28:1,2,5,7,11,15 expands [i] 7:16 

Commission s [z] 

copy [z] 4 :16 16 :8 develop p i [ ] 3) :24 32 :24,24 33 :10 expense [1] 24:5 

20:)9 32:2 

commitment [1) 2) :25 correct [1] 19 :15 developed [21 8:3 32 :3 electricity [1] 28:8 experience [i] 6:11 

common [1] 31 :8 corrected [i) 31 :11 developing [ll 8:24 eliminate [i] 25:11 

eliminated [i] 15 :4 

expires [1) 38:24 

explain [z] 13 :11 18 :5 

companies [1z] 19:20 

19:21 22:17 17 23:2 3 4 5 

correctly [i] 20:21 

Cost [21 9:]4 12:22 

development[i] 32:5 

deviate [i] 32:7 Elizabeth [3] 2:22 11 :4 explained [i] 23:2 ) 

, , , , 

23:9 25:16,17,20 couple[2] 9:24 20 :6 deviates [i) 30:19 

33 :24 explaining [i] 15 :19 

company [z] 15 :4 20 :4 Court [l] 38:22 differences [i] 24 :11 

emission [3] 3 :25 6:]4 

8'S 

explanation [i] 8:17 

complete [i) 4:9 cover [z] 10:15,25 different [i 1) 7:18 11 :8 emissions [s) 7 :6,14,22 

explanations [i) 8 :23 

explicit [i] 26 :19 completely [i 1 12:18 covers [41 7:11,16,17 8 :4 12 :6 13:3,24 16 :1,2 19:22 8:12,13 

compliance [2) 8:15 9:9 Crawford [i) 3:7 28:18 32:19,20 end [i] 13 :1 exposed [i] 6:12 

compliant [3) 8:25 9:11 CRB [41 9:7 21 :6,8,20 differently [3] 2:8 16 :25 energized [~] 27:15,18 express [3] 24 :25 28:17 

11 :2 

comply [3] 23:12 25 :25 

create[i] 35 :)4 

CSPA [~o] 19:19,19 20:4 

35:5 

differing [i] 22:24 

27;2) 28:2,7,832 :24 

enforce [1] 21 :23 

32:4 

expressed [z] 3 :25 32:25 

26 :21 22:16 23 :2,15 25 :23 27 :8 direct [z] 5:11 20 :4 enforcement [3] 24 :9 expressly [z] 25:10 

compound [41 6:15 29:21 30 :1 directly [3] 20:1 21 :3 24 :24 26 :1 35 :11 

24:18 34:2,12 Cumberland [i] 2:21 36:14 engaged [i1 6:13 extraordinary [1] 31 :4 

compounds [1z] 1 :7 current po] 7:9 19 :25 discernible [1] 28:3 

ensure [~] 33 :12 eyes [i] 31 :14 

2:17 6:1,3,19 11 :7 25:4 20:3 21 :16 23:19 25:23 discuss [11 5:24 

27:10 33 :5,5 34 :7 35:24 28 ;25 29:1,2,25 discussion [a] 2:)0 20:6 

ensuring [2] 24:23 31 :5 

entirel 1 24 :22 -Fcomprehensive [2) 30:4 

31 :12 

customer [i] 9:16 disease [1] 6:8 

y [ ] 

enunciated [i) 30:18 facilities [1) 19 :24 

computer-aided [l) customers [i) 6:24 disinterested [i] 38:13 nvironmental [~~] 1 :2 fact [z] 20:17 31 :3 

38:11 _ distin uished i ]9 17 

-D 

g [ ) : 2:2,14,16 4 :19 5:22 20 :23 fairly [2] 17:25 28:20 

concerns [ 4 ] 28:18 30:10 distribute [1] 19 :21 23:18 24:20 26:9 32:1 fairnes s p] 25 : 19 

32:5,25 Daily [z) 3:20,21 distributing [i] 8:25 EPA [is) 9:8 23:19,22 Falmouth [i] 2:22 

concluded [11 37 :6 damage [1] 6:7 distribution [3] 10 :)4 25 :1,6 32 :8,14,23 34:7 familiar[i] 18 :18 

conclusion [i] 29 :21 date [211 6:20 8:16,16,16 10 :24 23:1 35 :9,12,17,23,25 36:7 

' far[3) 2:208:1433:]9 

conducted [~] 3:15 8:18,19,2212:11,]313 :5 distributor [,1 10:20 EPA s [11 36:7 feasible [1] 9:20 

conflicted [i) 15:17 23:8 25:]5 27:4 28:23 

29:2,7,8,10,16,19 30:22 

distributors [z] 6:25 

9:10 

EPS [i] 25:10 

equivalent [1] 21 :22 federal [7] 3 :17 7:10,16 

Connecticut[3] 8:7 

10 :23 12:9 dead [i] 31 :2 district [z] 21 :11,11 Ernie [3] 2:20 15:21 

7:2014:10,)226 :3 

Federally [i] 13 :25 

consent [i] 2:11 deadline [i] 26 :24 

consequence [i) 29:6 deal [z) 22:23 33:19 

districts 

Division 

[2] 

[i) 

16

5:24 

:2 21 :11 

error 

30 :16 

[3) 26:14 29:4,5 felt [il 30 :2 

few [i] 3) :13 

consider[7] 20 :)823:]6 dealing [1] 22:2 Doesn't [1] 35:]4 errors[4] 26:1531 :10,13 

FIFA [s] 14:11 20:20 21 

24:)7 30:7 32 :22 33:11 

36:13 

deals [3] 21 :21 26 :4 33 :2 

decided i 18 :24 

Don [~] 2 :23 31 :17 

essential [z] 25 : ] 5, ) 6 

, considerable [i] 24 :4 25:24 27:2 

[ ) 

decides [i] 24:13 

done [5] 5:7 13 :21 29 :7,9 

33:19 establish [z] 6 :14 23 :7 figure [i) 16 :6 

considered [i] 29:25 define [1) 35 :4 draft [i) 4:17 estimate [1] 22:9 file [~) 26:]6 

final [s] 4:12 17 20:7 27:1 

considering [z] 11 :23 defined [z] 34:13 35:7 drafting [i] 31 :21 et [i] 27:22 8 , 

20:10 definition [33] 14 :23 Drive [z) 1 :15 2 :3 ethane [i] 34:8 finally [i] 21 :6 

consistency [3] 31 :5 17:20 18:9 24:17,19,21 due [i 1 17:2 evaporation [i) 7:7 financial [i] 22:1 33:12 35:15 

consistent[io] 1] :12 

24:22 25 :1,3,7,8,10 27:14 

28:21 30:25 32:12,14,15 

32 15 18 23 34 2 5 10 23 

during [1] 7:8 

g 

event [i] 38:14 

everybody [i) 27:23 

firstpo] 5:4,]5 10:18 

13:12 15:15 17:8 26:21 23:24 24:22 25:3,8 31 :3,9 

35:9,10 36 :7 

: , , : , , , 

35:8,12 36:4,6,7,8,9,15 -E- exact [1] 16 :8 32 :12 33 :1 36 :3 

consumer [35) 1 :8 2:18 definitions [3] 14:21 early [i] 20:12 exactly [1] 36:11 flexibility [2] 27:7 

6:2,16,19,23 7:10,13,17 

7:19 8:10 12 :3 16:10,15 

24:9 34:17 

degree [i] 30:17 

easier[21 10:17 31:15 EXAMINER [1] 2:6 

example [i] 36 :3 

29:16 

focused [i] 17:23 

16 :17 )7 :20 18 :6 19 :13 Delaware [1] 8:7 

easy [1] 31 :]5 

effect [ill 7:11 10 :16 22 Examples [11 7:2 fogger[r] 13 :20 

19:18,22 20:22 21 :2,4,7,8 

21:12,23 22 :4,6,7,11 den [i] 4:10 3' 

, 

15 :2 20:4 23 :21,21 26:22 excuse [i) 24:2 follow [3) 27:24 29:8 

33 :17 

23:20 26:5 32:2 36:14 DEP [z) 9:8 30:3 29 :3,3,10 executive [i] 3 :3 follow-up [i] 11 :5 

consumers[z) 9:13 Department[21] 2:15 effective [7) 8:19 12 :11 exempt [3] 13 :19 14 :13 following [4] 4:17 5:10 12 :21 3:8 4:18 5:22 8:17 9:3 12 :13 23:8 25 :15 29 :2,16 35 :25 

20:]5 32:23 

consuming [i] 26 :)2 20:10 23:16 24:3,15 28:17 

29:25 30:1 6 12 31:2 4 18 

effectiveness [i) 13:3 exempted [l] 27:17 

follows [i] 27 :23 

containerp] 15:8 

, , , , 

31 :25 32:22 33:10 efficiency [i] 35:13 exemption [i) 15:10 

forcing [z] 22:22 30:5 

Index Page 2 
forefront [21 20:13,17 

foregoing [il 38 :9 

Foreside [1l 2:22 

form Ell 6:5 

formal [il 4:18 

formulate [21 19:21 

27:13 

formulated pl 28:6 

Fort Ell 2:24 

forth [il 24 :19 

fortunately [21 32 :4 

35 :20 

' forum [il 31:7 

forward [81 24:14,15 

25:6,14 30:6,7,11,12 

found [il 28:22 

Fourth [il 27:8 

frequently (i 1 34:19 

fruit Ell 17:15 

FTES Ell 22:12 

full-time Ell 21:22 

function [i] 6:6 

fundamental [i] 25:19 

Fungicide Ell 14:12 

furthermore p1 26:13 

-GI general [31 3:2 19:19 

35:8 

Ginny [21 2:13 14:8 

glad (il 17 :17 

go-around [il 15:15 

goal Ell 33:11 

goes [61 8 :15 25 :6,14 30:7 

30:12 31 :14 

gone [i1 12:7 

good [sl 2 :6 5:16,17 13 :8 

15 :20 

Gould [1l 2:23 

Greenville (il 2:23 

group Ell 32:3 

groups [2] 16:6 22 :8 

guess [2] 16:15 31 :14 

guessing [il 36:5 

Guimond [il 2:23 

-Hhair pi 19 :9 

half [31 12:12,13 19:10 

Hampden [il 2:25 

Hampshire [31 8:8 10:23 

24:25 

hand [41 4:24 26:8,10 

38:18 

hands pi 31 :15 

hanging [il 17:14 

Hanson [il 3:5 

happy [il 30:13 

hardly Ell 32:21 

health [21 28 :9,14 

Healthy Ell 6 :10 

hear Ell 5:15 

heard pi 19 :9 

hearing [isl 1 :152:1,6,9 

2:15,19 3 :10,15,18,22 4:2 

4:7,7 37:5,6 

hearings Ell 33 :15 

held (51 1 :15 2:1 3 :10 

9:11 29 :17 

help [21 16 :6 36:23 

Herald [i] 3:21 

herbicides [1l 21 :5 

hereby [il 38:4 

hereunto [i] 38:17 

' high Ell 34 :11 

higher [il 17 :16 

Hilton [18] 2:20 15 :22 

16:9,14,20 17:5,11,17 

22:4 30:17,22 31 :20 32:6 

32:10,16 33 :22 35:14,19 

holding [il 2:14 

Holiday [2] 1 :15 2:2 

home (31 13:19 14:4 15 :7 

homeowner [il 17 :24 

hospitals [1l 7:2 

household [21 7:4 15 :8 

-I- 

! idea [21 11 :11 16:21 

identify [21 29:23 31 :17 

identifying Ell 29:6 

immediately [il 28 :3 

impact [21 7:9 25:5 

impacted Ell 25:20 

implement Ell 16:6 

Implementation [z] 

3:14 4 :20 

importance [21 22:20 

24:10 

important [4] 25 :19 

29:15 30:13 33 :20 

I impressed [il 19:8 

include [71 6:18,23 7:3 

13 :15 16 :20 34:18,24 

included Ell 13 :16 

inclusion [21 4:6,20 

incorporate [21 25:1,10 

incorporates [21 20:8 

24:19 

increase (21 7:24 12 :24 

increased pi 6 :11 

increases vi 9:15 

indicate [il 4:15 

individuals Ell 6:11 

industrial [3] 18 :1,4,20 

inflame (i] 6:7 

information [2] 9:3 

12 :17 

initial Ell 7:21 

Inn [2] 1 :15 2:2 

innovative Ell 9 :5 

insect Ell 13 :20 

insecticide [21 14:12,23 

CondenseIt! ' 

insecticides [21 7:5 21 :5 

insects Ell 14:25 

instance (41 21 :10 31 :1 

35:24 36:1 

instances [il 33 :7 

Instead (i] 29:6 

institutional [ii 7:1 

institutions [21 17:24 

19:24 

instructions [il 27:25 

intended [il 26:24 

intent [2] 36:4,6 

interest [il 4:1 

interested [i] 5:6 

interplay [i] 19 :5 

interpretation [21 24 :8 

24:23 

inventory [il 7:13 

involved [21 31 :20,21 

irritate [il 6:5 

Island Ell 8:8 

issue [9l 20:14 28 :9,16 

30:13 32 :12,25 33 :2,4 

35 :11 

issued [il 9 :6 

issues [6] 28:19 29:23 

30:22,23 31 :18 32:20 

items [3] 2:12 12:25 15:2 

_j_ 

January [sl 12:11 20:12 

23:7 25:14 29:14 

Jeff [i] 3 :7 

Jersey [2] 8:8 12 :8 

Joanne [31 3:6 38 :3,21 

job [21 31 :4,15 

Joe (31 19:13,18 34:16 

Journal [21 3:19,20 

Julian Ell 8:21 

July [31 3:19,22 38 :24 

jurisdiction Ell 15 :13 

-Klarge [41 17:4 18 :2 21:20 

35:23 

largely Ell 35:9 

largest [il 21:1 

last Ell 17:21 

Law [i] 3 :11 

lawyer [il 36:10 

lead [il 20:16 

left [il 3 :3 

legislation [21 11 :7 12 :7 

legislature Ell 22 :11 

legitimate [il 33 :7 

less [4] 6:22 8:21 9:16 

15:6 

Lessard [s] 2:24 11 :21 

12:15 

letter [il 10 :19 

level [31 9:1 10 :14 21 :25 

levels Ell 26 :6 

Lewiston Ell 3:20 

license (il 15 :3 

licensed Ell 3:24 

likelihood [i] 11 :1 

! likely Ell 10:24 

limit Ell 27:17 

limitation Ell 18 :16 

limitations Ell 18:10 

limited [21 33 :6,9 

limits [151 6 :14,18 7:20 

8:1,5 9:18 11 :6 16:3 18:11 

21 :18 22:15 24:12 26:1 

27:3 31:2 

line Ell 12:20 

lines Ell 35:15 

lining [il 6:7 

list [21 3 :24 10:11 

liStS [2] 25:4 34:6 

local [31 35:17,20,22 

locking [i] 26:23 

look [4] 14:18 19:5 30:5 

30:11 

looking [2] 11 :14 17:19 

low [i] 17:14 

lung [zl 6:6,8 keepp] 11 :12 

keeping [i] 6:21 

Kennebec [21 3:18,19 

Kent Ell 2 :24 

kind [31 10 :15 17 :5 18 :5 

-Llabel Ell 27:24 

labeled [21 13 :16 27:19 

labels Ell 13:5 

language Ell 27:5 

Lani [s5] 3:8 5:15,17,21 

5:21 10:1,4,13 11 :9,16 

12 :1,16,23 13 :2,13,18,23 

14:3,16,18 15 :14,24 16:13 

16:17,24 17 :8,12 18:7,13 

18:23 19 :3 23 :20 34:16 

34:22 35:4 

lungs [i] 6 :8 I 

-MM.R.S .A [1] 3:11 

ma'am [21 19 :15 36:24 

machine [11 38 :11 

mailing Ell 3:24 

Maine [341 1 :1,15 2:3 

8 :10 9:17 11 :17 13 :24 

19:25 20:13,16,17,24,25 

23 :4 24:1,5,18,21 25:7,9 

25:17 26:10,11 29:24 30 :3 

31 :7,25 34:6,14 35:25 

36:9,10,20 38:4 

Maine's [4] 3:14 20:15 

25:3 26:2 

makes [2] 10:16 26 :19 

manufacture [2] 19:21 

forefront - Ms 

23 :3 

manufactured [ii 8:19 

manufacturer's Ell 

27:23 

manufacturers [91 6 :22 

8:15,21,24 9:2,10 27:13 

27:24 35:16 

manufacturing [2] 

35 :16,17 

marked (il 4:5 

market Ell 22:18 

marketed (i] 6:24 

Maryland [21 8:7 20:12 

Massachusetts [41 8:7 

10 :22 12 :10 20:11 

materials pi 15 :6 

Matt [4] 3:1,4 9:23 12:19 

Matt's Ell 11 :6 

matter [41 23 :15 24:10 

25:18 35 :12 

may [231 6 :11 17:1,2,3 

19:5 21 :10 23:5,9,14 

25:21 26:20,22 28:2,4,19 

29:3,13 31 :13,16 35:24 

35:25 36:2,16 

mean [2] 31 :7 35:16 

means [21 14:23 38:10 

meet Ell 8:19 

meeting Ell 4 :12 

member [31 2 :24 20:4 

32 :1 

members [sl 2:19 4:9 

5:11,18 19:17 

mention Ell 28 :20 

mentioned [sl 8:1 9:25 

11 :21 12:4 22:16 25:13 

28:19 34:19 

methane Ell 34 :8 

methylene [1l 27 :12 

Mid Ell 8:4 

might pl 10 :20 12:4,22 

12:24,25 33:8,10 

mind [3] 14:19 21 :24 36:3 

minimums Ell 18:17 

minor [31 29:4 31:10,13 

miscellaneous Ell 7:6 

mistake [il 22:21 

model [21] 8:2 11 :11,17 

15:23 16:5 19:4 20:9 

21 :16,16 22:13 23:25 27:6 

29:9 30:19 31 :3,25 32:11 

32:13 33 :17,18,21 

modified (il 11 :10 

modify [il 6:20 

morning [41 2:6 3 :20 

5:16,17 

Morrisette Ell 3:6 

Most [31 6:10 22:2 35:23 

mostly [j] 21 :5 

MS [44] 5:17,19,21 10:1,4 

10:13 11 :5,9,14,16,18,21 

12:1,15,16,23 13 :2,18,23 

14:3,16,18 15:14,24 16 :13 

16:17,24 17:8,12,19 18:7 

Index Page 3 
18:12,13,22,23 19 :3 23:20 

33 :25 34:16,20,22 35:1,4 

36:21 

must [31 10 :10 26 :8,10 

-Nname [2] 2:13 19 :17 

Nancy [21 2:21,25 

narrow [i] 27:16 

national [4] 7 :13 23:19 

24:5,7 

nationwide [2] 22:18 

23:1 

necessarily (i1 14 :16 

necessary [i] 27:6 

need [1] 29 :23 

needs [21 28:16 29:15 

negligible [1] 25 :5 

neither [2] 5:6 19 :12 

network [i] 10 :24 

networks [i] 10 :15 

never [i] 19 :9 

new [81 8:8,8,8 10:23 12 :8 

24 :25 26:19 28:23 

News [1] 3:22 

next [3] 2:21 3 :4 5:9 

nicely [1] 29 :20 

nitrogen [i] 6:4 

non-starter [i] 32 :18 

none [3] 15 :14,17 37 :4 

nonflammable [2] 

27:13 28:6 

nor[i] 5:6 

Northeast [2] 8:4 16:7 

Notary [i] 38 :3 

nothing [2] 5:1 38:8 

notice [61 1 :15 3 :17,22 

3 :24 9:13 13 :4 

now [6] 5:8 14:1 17:16 

20:14 23 :10 33:18 

number [io] 10 :2 11 :22 

21 :1 23:2,5 25:4 30 :18 

32:6 34:6 36:9 

-0- 

object [1] 28:14 

obligations [i] 9 :9 

obvious [1] 36:5 

occasionally [1] 25 :6 

off (i] 33 :13 

officer [2] 1 :12 2 :19 

one [i9] 8:14 11 :14 13 :9 

18:1 20:13 21 :13 22:23 

25:25 26 :8,20 27:4 28:19 

28:20 29 :13 31 :5 32:21 

32 :22 33 :9 35:24 

onerous [2] 6:22 8:21 

ones [2] 11 :24,25 

open [21 4:3 31 :24 

operate [i] 14:6 

opponents [1] 5 :5 

opportunity [3] 5 :11 

30:10 33 :15 

, opposed [i] 24:6 

opposition [i] 19 :13 

option [7] 9:4 23 :17 

32:21,22 33:8 36:12,16 

options [i] 32:13 

organic [9] 1 :7 2:17 6:1 

6 :3,15 7:8 24:18 34:2,11 

organization [i] 31 :21 

OTC [171 8:6 16:3 18:23 

19 :3 20:9 21 :16,16 22:13 

23:25 27:6 29:8 31 :3,23 

32:13 33:1,1,17 

OTC's [11 31 :21 

outcome [i] 38:14 

oxides [i] 6 :4 

ozone [9] 6:5,5,12 8:3 

20 :18 31 :6,8 32 :2 33 :2 

_P_ 

~ 

P [21 38 :3,21 

p.m [i] 4:3 

packages [i] 13 :16 

packet [41 13:12 14:21 

]4 :22 18:8 

page [71 13 :12 14 :19 

17:20 18:8 19:8 26:18 

28:22 

pages (i] 14:20 

paint [2] 17 :721 :10 

paramount [2] 22:19 

24:10 

part [4] 3:16 17:2 34:20 

35:2 

particularly [i] 25:16 

parties fil 5:6 

pass [i] 16 :2 

passed [2] 10:18 12:9 

patchwork [i] 22:24 

pay [i] 13 :4 

Peggy [l] 3:1 

Pennsylvania [i] 24:25 

people [2] 28:1 31 :16 

per [s] 7:23 8:12 9:16,17 

9:25 

percent [7] 7:12,14,22 

17 :10,13,13 18 :13 

perchloroethylene [i] 

27:11 

performance p] 9:14 

perhaps [1] 5:20 

person [1] 38 :14 

personal [i] 7:3 

personally [i] 38 :5 

personnel [i1 21 :25 

persons [2] 3:23 4:22 

perspective [1] 24:7 

pertains [3] 21 :12 31 :1 

32 :23 

pest [i] 15 :3 

pesticide [5] 13 :24 14:24 

15:16 20:24 26:11 

CondenseIt! T' 

pesticides [3] 13:15,18 

15 :11 

photoreactive [i] 25 :5 

physical [1] 6:13 

pick [i] 28 :5 

piecemeal [i] ]6 :1 

place [31 8:6 36:9,11 

places [1] 7:19 

plan [4] 3 :14 4:21,23 5:7 

Planning [i] 5:23 

plans [i] 9:6 

play [2] 15 :9 17:3 

Plummer [281 1 :12 2:13 

5 :3,17 9:22 11 :4,19 12:19 

13:7,9,14,21 14:1,9 15 :21 

17:18 19:1,7,16 30:15 

33:23 34:10,15 36 :18,21 

36:23,25 37:3 

plus [i] 35 :21 

podium [i] 5:9 

point [3] 12:15,16 35:2 

points [i] 20 :6 

pops [i] 36:3 

Portland [21 2:25 3:21 

possible [2] 23:17 28:4 

potentially [4] 12:23 

22:24 24:12 35:4 

practical [2] 24 :10 27:22 

premised [i] 21 :17 

prepare [i] 4 :18 

presence [1] 6:4 

present [2] 3:7 30:10 

presentation [i] 5:10 

presentations [i] 5:4 

~ presented [i] 4:14 

presently [i] 4:15 

presiding [2] 1 :12 2:18 

Press [1] 3 :21 

pressurized [1] 17 :1 

pretty [1] 10 :5 

previous [i] 14 :22 

proactive [i] 11 :1 

problem [51 27:18 29:20 

31 :8 35:11,15 

problems [2] 6:10 33 :21 

Procedures [i] 5:3 

process [6] 8:9 12:1,6,8 

23:22 31:24 

produced [i] 9:25 

producers [i] 10:10 

product [211 7:11,13,17 

7:19 9 :5,14,15 12 :22 

14 :24 15:8 16:18 17:20 

21:23 26 :5 27:14 28:12 

28:21,22 29:14,17 31 :1 

products [69] 1 :8 2:18 

6 :2,16,20,23,23,24 7:3,3 

7 :4,5,6,7,10,18 8 :11,16 

8 :18,25 9:11,17 10:12,17 

10:21 11 :2 12:3 13 :3 14 :5 

14:13,25 16:17,25 17:25 

18:16 19:9,14,19,23,23 

20:4,20,21,22 21 :1,2,3,4 

21 :8,8,9,13 22:5,6,7,12 

22:18 23:1,12,20 25:22 

25:25 26:7,8 27 :2,13,16 

32:3 36:14 

Program [i] 5:23 

propellant [2] 7 :8 17 :2 

properly [i] 13 :16 

proponents [i] 5:4 

proposal [1] 23 :7 

proposals [i] 32 :8 

proposed [17] 2:15 4:10 

5 :13,25 6 :13,18 7:24 8:2 

8 :12 9:18 11:7 20:1,3 

24:14 27:9 29:12 30:19 

proposing [s] 20:11 

23 :25 24:3 

prospects [i] 32 :9 

Protection [n] 1 :2 2:2 

2:14,16 4:19 5 :23 20:23 

23:18 24 :20 26 :9 32 :1 

provide [i] 25:24 

provided [2] 16 :10 22 :10 

provides [2] 27 :6 31 :7 

providing [1] 26 :25 

provision [i] 26:2 

provisions [7] 9:2 20 :8 

21 :19 24 :9 25:23 26 :1 

27:3 

public [61 2:9,15 3 :11 4:7 

38:3,22 

published [i] 3:18 

pull [i] 18 :3 

purpose [1] 26 :25 

pursuant [3] 1 :15 3:10 

3:16 

pursue [i] 18 :25 

put [6] 24:15,19 33 :2 34:5 

36 :9,11 II 

quality [61 3:15 4:5 5 :16 

5:23 9:14 22:3 

quantities [3] 17:25 18:3 

18:10 

questions [13] 5:12,14 

9:21,22,24 11 :19 13:7 

19:8,11 30:14,16 33:23 

36:25 

quite [7] 12 :9 21 :1,20 

22:3 23:8 28:4 35:9 

quote [i] 27:4 

-Rraise [i] 4:24 

raised [i] 20:6 

raises (1] ]4:7 

raising [i] 36:16 

range [2] 19:20 22:17 

rate [i] 16:24 

rather [2] 22 :23 31 :4 

RE [i] 1 :7 

reaching [1] 17 :15 

react 1j] 6:3 

read [11 27 :24 

must - require 

reading [il 36 :5 

real [i] 31 :5 

realities [i] 27:22 

really [7] 16 :10 17 :5,23 

18 :329:1532:1835:13 

reasonable [4] 22:3 23 :8 

26 :5 30 :3 

reasons [2] 28:15 33 :7 

receive [3] 4:16 26:8,11 

recommendation [i] 

4:]2 

record [5] 4 :2,7,9 6:21 

38:10 

recorder p] 3:5 

recording [2] 3:6 6:22 

reduce [31 6:6 8:13 17 :6 

reduced [1] 7:21 

reduces p] 7:13 

reduction [s] 10:2,8 24:1 

reductions [i] 17:14 

reference [2] 25:1 26:20 

~ referencing [1] 35:12 

referred [i] 28:24 

reformulate [3] 23:11 

25:21 26:7 

regarding [2] 17 :21 

20 :20 

Region [1] 8:6 

regional [3] 10:14 23 :3,9 

registered [i] 21 :2 

regular (2] 2:11,12 

regularly-scheduled 

[i] 4:11 

I regulated [5] 20:20,21 

21 :10 25:24 27:2 

regulates [i] 21:8 

regulation [23] 6:2 7:10 

9:7 19 :25 20:1,3,8,22 21 :7 

21:14,14 22:19 23:6,10 

24:24 25:21,24 26:5 28 :25 

30:5 34:14 36:11,14 

regulations [1o] 3:17 7 :9 

8 :10 14 :10 21 :17,21,23 

22:25 24:11 35:2 

regulatory [1] 3 :24 

related [2] 14 :6 26:1 

relatively [21 25:3 36:6 

relevant [i] 36:15 

rely [i] 24:5 

remain [i] 4:3 

remember [2] 13 :10 14 :2 

remove p] 28:10 

rephrase [2] 22:7 34:8 

report [1] 22:10 

Reporter/Notary (i] 

38:22 

reporting [1] 9:1 

represent [21 23 :4 25:18 

represents [3] 19 :20 

22:16 23:2 

request [2] 4:13 27:1 

requests [i] 9:3 

require [2] 9:2 15:3 

Index Page 4 
Irequired [il 8:15 

requirement pi 8:20 

requirements [sl 3:16 

6:21 8 :20 9:15 22:14 

resolved [21 29:24 35 :11 

resolves [1l 29:19 

resources [41 21 :6,15 

22:1,10 

respiratory [31 6 :6,10 

6:12 

respond [il 5:2 

responsible [2] 8:11,24 

restricted [2] 15 :6 33 :6 

restriction [31 27 :9 

28:10 33 :3 

restrictions [1l 28:13 

result [21 7:7 13 :1 

retail [2] 6:23 9:1 

retailer [il 10:20 

retailers [3] 9:10 10:10 

10:25 

retention [il 26 :13 

review [il 26:6 

reviewing [il 31 :16 

revised [61 20:9 21 :16 

23 :25 26:19 27:1 28:10 

revises pi 23:19 

revising [31 23:23,23 

24:17 

revision [il 3:13 

revisions [31 20:9,18 

30:8 

Rhode [i] 8:8 

Richard [il 2:23 

right [8l 2:20 3 :1 4:24 

13:2,6 17:8 20:14 29:21 

risk [ii 6:10 

river p 1 2:10 

Ron [i] 3:8 

room [il 4:15 

rule [6ol 4:13 5 :13 6:17 

7:16,20,21,21 8:2,22 

10:12,16,22,24 11 :12 

14:14 15:22,23,23 16 :5 

16:11,19 17:8,21,23 18:8 

18:24 19:4 20:9,19 21 :3 

23:20,20,23 24:6,6 26:2,3 

26:3,4,19,21,22,25 27:1 

28:10,25 29:1,2,11,12 

30:1,8,19,20 31 :25 32:11 

32:13 34:21,22 35:5 

rulemaking [41 12 :8 

20 :11,12,14 

rules [91 4:1,17,18 8:5 

15:24 16 :2 31 :22 32:3 

34:24 

_S_ 

safety [2] 28 :9,15 

sale [21 8 :25 13 :15 

save [il 24:3 

says [21 29:13,13 

scale [21 17:4 22:13 

scaled [il 21 :18 

schools [1l 7:2 

Scoff [i41 3 :1 9:24 10:2,7 

11 :3 12:20,24 13:6,8 14 :7 

14:10,17 15:11,19 

'sealants [il 7:5 

seasonal [i] 16:22 

seated [1] 3:4 

second [sl 5:5 14:20 

23 :16 25:13 29:13 

Secondly[l] 20:19 

section [sl 3 :11,12 26:19 

28 :23 34 :14 35:8 

See [61 6:17 12 :22 17 :11 

29:11 32:16 33:22 

seeing [2] 16:11 37:4 

seem [l] 30:17 

sell [21 10:21 19:22 

send [ii 8:23 

sensibilities p] 16:9 

sent [21 3 :23 10:19 

sentence [i] 17:21 

Sentinel [il 3 :21 

separate [i] 34:13 

September [31 7 :15 

28:24 38:18 

Services [il 3 :7 

set [41 20:2 22:23 32:19 

38:17 

settings [1l 7:1 

several [21 28:18 29:23 

Severance [1] 3:8 

shall [il 4:3 

sheet [31 4:14,16 5:9 

shops [1l 7:1 

shorthand [il 38:11 

side [i] 5 :13 

sign [il 5:8 

significant [sl 22:2 

28 :21 29 :5 

similar [sl 8:10 9:7 22 :16 

24:21 35:23 

six [il 28:11 

size [il 15:8 

slight[l] 24:11 

small [61 10:5 12:24 15:7 

17:25 23:2 25:16 

sold [21 6:23 19:23 

solids [11 7 :g 

solvents [21 28:13 33:3 

sometimes [21 27:12,25 

somewhere [i] 13 :22 

sorry [31 7:23 18:17 19 :3 

sort [21 15 :25 20:15 

sources p1 3 :25 

South [il 2:25 

speak [41 5 :7 16:24 19 :1 

37:4 

speaker [l] 19:12 

speakers' p1 5:8 

Specialty [2] 19:13,18 

specific [sl 24:6 27:16 

29:6 32:14 34:24 

CondenseIt! ' 

specifically [sl 19 :4 

25 :17 27 :11 30:25 36:19 

specified [11 27:4 

staff [31 3:9 4 :12 21 :20 

staffers [il 21 :22 

stage [i] 20:7 

stakeholder [z] 16:5 

31 :23 

stakeholders [21 30:2,7 

stand [i] 4:23 

standard [l] 35:18 

standards [i31 20:2 

22:20,22,23 23:13 24:8 

27:5 29:2,3,10,11,19 

35:17 

Starks [i] 2:20 

start [21 2:8 23:14 

started [41 12:9 17:14 

20:11,12 

starting [il 20:14 

state [2s1 1 :1 3 :14 4:20 

7:14,219:7 10:17,20 12:6 

20:7,17,25 21 :24 22 :25 

24:6,11 26:4 27:1 29:9 

32:14,20 33:12,13 35:15 

38:4 

states [19] 8:4 9:19 10:15 

10:25 11 :8,10,22,24 12:2 

12:14 20:15 23:19 24:24 

27:20 31:8 33 :14,17 35:10 

35 :23 

statewide [31 21 :9,13 

35 :21 

statute [i] 21 :14 

step [2] 25:9,12 

Still [21 18:9,16 

stocking [1l 9:11 

straight [ii 27:5 

straightforward [il 

25:2 

stringent [2] 7:20 22:22 

structural [il 15:3 

structure [il 16:11 

sub-category [il 27:16 

subject [9] 4:1 9:8 20:22 

21 :4,13 23:6,10 27:3 

28:12 

subjected [2] 18 :11 21:3 

I submit [41 8 :16 9:2 32:17 

33:16 

submittal [il 4:19 

submitted [i1 3 :13 

submitting [2] 9 :4 29:22 

Subsection [1l 28:23 

substantially [1] 17:7 

such [51 7 :1 21 :9 24:24 

27:22 34 :7 

Sue [21 2:24 11 :20 

sufficient [il 23:11 

suggest [41 24:16 26:14 

28:9 32:22 

suggesting [2] 33:9 

36 :12 

suggestions [i] 34:1 

summary [3] 19 :25 

29:24 30:2 

Sun [1l 3:20 

sunlight[l] 6:4 

support [41 19:12,12 

26:13 27:8 

supports [1] 25:23 

supposed [i] 27:19 

surface [21 28:7,7 

surfaces [il 27 :21 

surprised [i] 17 :5 

surprising [il 31 :13 

swath [il 11 :13 

sworn [21 4:23 38:7 

symptoms [i] 6:12 

system [1l 6 :6 

-Tt [il 36:1 

table [5l 5 :13 6 :17 27:5 

29:11,19 

taking [il 14:19 

technical [71 26:14,15 

28:19 29:5,23 31 :10,17 

technologically [il 

9:20 

technology [21 22 :22 

30:4 

term [3] 28:22 29:14 

30:25 

termites [i] 15:5 

terms [8] 14 :4 15:6 21 :6 

21:7,25 30:22,24 32:21 

Terry [il 3:5 

testify [31 4:23 33:15 

38:7 

testimony [31 4:4,25 

5:15 

thank [14] 5:3 11 :3,18 

13:8 15:19 18:22 19:11 

19:16 30:9,15 34:9 36:24 

37:1,2 

theirs [51 11 :10 12:9,10 

12:11,14 

they've [il 12:7 

thinking [il 36:1 

third [21 5:5 25:23 

thorough p] 31 :10 

three [11 32:13 

threshold [i] 23:15 

through [5l 5 :12 12:7,7 

15:16 26:7 

throughout [il 32:5 

times pi 16:3 

Title [il 3:16 

today [6] 2:8,15,20 3:5 

5:24 16 :12 

today's [7] 2:19 3 :10,15 

3:18,22 4 :2,7 

ton [21 8:14 10:5 

tons [61 7:23 8:11 9:25 

16:14,22 17:9 

took [51 16:3 21 :17 26:22 

required - VOC 

29:3,3 

tough [3] 22:21 23:12 

33 :17 

toxic [31 6:19 8:1 33:4 

transcribed[l] 4 :8 

transparent [2] 9:12 

31 :24 

transport [sl 8:3 20:19 

31 :6,8 32:2 

tree [1] 17:16 

true [2] 20 :25 38 :9 

truth [51 4:25 5:1 38 :7,7 

38 :8 

truthfully [2] 21 :1,20 

try [il 9:21 

trying [ij 33 :20 

turn [i] 18 :7 

two [9] 7:22,23 17:9 22:8 

22:11 26:6 29:12 32:21 

35:24 

two-tenths [31 8:14 10:4 

10 :8 

two-thirds [21 20:2,2 

type [2] 10:21 15:8 

types [41 7:2,18 19:22 

21:9 

_U_ 

U.S [51 4:19 20:23 23 :18 

24:20 26:9 

under [81 10:12 13:23 

14:10,14,15,18 15:12 20:3 

undercuts [i] 26:24 

undermines [il 26 :24 

understand [21 1 o:11 

15 :25 

understandable [il 

22:13 

Unfortunately [21 

26:23 34:4 

uniform [41 22:23 24:7,8 

24:23 

uniformity [21 22:19 

33 :19 

unless [s] 11 :9 13 :4 

34:24 

untenable [i] 23 :1 

unworkable [i] 24:12 

up [41 9:16 17:16 19:2 

28:5 

urge [i] 23 :15 

used [61 16:4 18:2,14 

27:12,20,21 

uses [4] 18:1,4,15,20 

usually [il 34:23 

_V_ 

variances [il 9:5 

version [il 10:19 

versus [31 16 :10 28:2 

32:24 

Virginia [21 1 :12 8:9 

VOC [ia] 7:6,14,20,21 

Index Page 5 
CondenseIt! "" VOCs - Ziegler 

8:12 9:18 14 :5 16:15 17 :2 

21 :18 22:15 24:12,18,22 

25 :25 27:3,17 31:2 

VOCS [6] 6 :3 9:25 17:6 

24:2 32:12 36:15 

volatile [8] 1 :7 2:17 6 :1 

6:3,14 20:19 24:18 34 :2 

volatility pi 34:11 

vote p] 4:10 

-wwait pi 18 :16 

Waterville [il 3:20 

ways [i] 32 :7 

whereas pi 25 :9 

WHEREOF [1l 38:17 

whole [2] 17:23 38:7 

wholesale [21 6 :25 9:1 

wide [i] 22:17 

wish [21 4:16 37:4 

within [31 7:19 32 :2,11 

within-named pi 38 :6 

WITNESS [1l 38:17 

witnesses [2] 5:2 38 :6 

wondered [il 10 :7 

worked [2] 15 :16 30 :1 

write [11 15:23 

writing [il 16:4 

written [6] 4:2,4 26:16 - 

29:22 33 :16 36 :18 

wrong [i] 29 :7 

-yyear [61 9:17 12 :12,13 

25 :25 26:20 27:4 

years [i] 36 :10 

yet [21 12 :10 32:6 

York p1 8:8 

Yost 116] 19:13,15,18 

22:6 30:21,24 31 :23 32 :10 

32 :17 34 :4,13 35 :7,19 

36:21,24 37:2 

yup [sl 13:13 14:2 15 :14 

-ZZiegler [il 2:25 

Index Page 6