November 16, 2010 via e-mail

Air Resources Board 1001 I Street, 23rd Floor Sacramento, California 95814

Attn: Ms. Lori Andreoni Manager, Board Administration a nd Regulations Coordination Un it http://www.arb.ca.gov/lispub/comm/bclist.php

Subject: Comments on Proposed Amendments to the California Consumer Products Regulation; Board Agenda Item # 10-10-7

Dear Board Members:

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

comments to the California Air Resources Boar d (ARB) on the proposed amendments to the state’s comprehensive Consumer Products Regulation. 1 The proposed amendments will add and/or modify product category de finitions and establish 15 new or lower VOC limits for broad categories of consumer products. The propos ed new limits on volatile organic compounds (VOCs) will result in additional emission reduc tions of approximately 6.9 tons per day once fully effective. CSPA member companies manufacture or market all of the pr oducts included in the proposed 2010 Amendments. In most cases, CS PA member companies manufacture the leading product brands on the market.

CSPA submitted two sets of initial comments in a letter dated May 28, 2010, and a letter dated August 16, 2010. CSPA’s positions st ated in these earlier document s are hereby incorporated by express reference in the current commen ts that we are submitting today.

CSPA participated as an active member of the ARB’s Consumer Products Regulation Workgroup (CPRWG). We commend A RB staff’s efforts to ensure that all interested parties had an opportunity to participate in this open and transparent public effort to develop the proposed amendments that are presented to the Board fo r your consideration. Throughout the course of the current rulemaking process, CSPA worked cooperatively with ARB staff, environmental groups, air districts and various other stakeholders to iden tify potential opportunities for reductions in the VOC content of consumer produc ts in the hope that these challenging new regulatory limits will prove to be technol ogically and commercially feasible.

1 The text of the proposed amendments to the Ca lifornia Consumer Products Regulation is posted

on ARB’s website at: http://www.arb.ca.gov/regact/2010/cp2010/cpappa.pdf . The ARB “Staff Report: Initial Statement of Reasons (ISOR),” notice of the public hearing and other relevant documents are posted at: http://www.arb.ca.gov/regact/2010/cp2010/cp2010.htm

.

900 17 TH STREET, NW, SUITE 300, WASHINGTON, DC 20006 (P) 202.872.8110 (F) 202.872.8114 WWW.CSPA.ORGCSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 2 of 19

CSPA member companies take seriously the envi ronmental health and safety benefits of our products, and continuously seek to improve them . Therefore, CSPA member companies commit to expend the time and money to develop the ne w technologies necessary to reformulate their products to meet the aggressive and technology-fo rcing VOC limits such as those that will be established by this pr oposed regulation.

CSPA’s commitment to meet this new challenge is consistent with our member companies’ longstanding efforts to work constr uctively and cooperatively with ARB staff, environmental groups and other stakeholders. During the past 21 years, CSPA member companies spent hundreds of

millions of dollars to lower VOC content in cons umer products to help improve air quality in California while maintaining our industry’s ability to supply effective pr oducts that consumers can rely upon to contribute positively to th eir health, safety, and quality of life.



### S TATEMENT OF 

### I NTEREST

CSPA is national trade associa tion representing the interests of approximately 240 companies engaged in the manufacture, fo rmulation, distribution and sale of consumer and commercial products that help household and institutiona l customers create cleaner and healthier environments. CSPA member companies’ produc ts include disinfectants that kill germs in homes, hospitals and restaurants; air fresheners that eliminate odors; pest management products for home, garden and pets; cleaning products and polishes for use throughout the home and institutions; products used to protect and improve the perf ormance and appearance of automobiles; and a host of other products used every day. These products are formulated and packaged in many forms and are generally market ed nationally. Through its product stewardship program Product Care ® and scientific endea vors, CSPA provides its members a platform to effectively address issues regarding the health, safety, sustainability and environmental impacts of their products.



### C OMMENTS

A. Comments on Proposals for Specific Product Categories

1. General Purpose Cleaners (non-aerosol)

The proposed new VOC limit, if adopted by the Bo ard, will constitute the third time that ARB has regulated this form of the General Purpose Cleaner product category. CSPA continues to be extremely concerned about the proposed 0.5% VOC limit that would be applied to more than 1,500 products in the category reported in the 2006 Survey. Based upon extensive technical evidence that we have shared with ARB staff, CSPA continues to believe that the very aggressive proposal of 0.5% VOC limit for all pr oducts in this broad category pushes almost to the breaking-point the envelope of technological and commercial f easibility. This limit is very difficult for spray-and-wipe surface cleaners a nd wipes, non-aerosol product forms in this category that do not utilize large quantities of (oft en heated) water for cleaning, and must rely on

other mechanisms to achieve effective soil removal.

Although our member companies continue to have serious concerns, CSPA is not opposing a 0.5% VOC limit for the vast majority of general purpose cleaners.CSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 3 of 19

However, CSPA continues to urge ARB to provide a higher VOC li mit for two product subcategories – General-purpose Cleaners in wipe form and Special-purpo se Floor Cleaners.

a. CSPA urges ARB to consider adopti ng a 2% VOC limit for General-purpose Cleaners that are sold in wipe form

.

A consumer use study conducted by one of CSPA ’s member companies found that twice as much liquid is used when consumers use a trigge r form of product to clean a given surface area than is used when cleaning the same surface area with a wipe pr oduct. Taking into account the market share of trigger and wipe cleaning products, the resulting consumers use is approximately four times as many products in trigger form than wipe forms to clean a given surface area. 2

Assuming a 0.5% VOC limit for triggers and a 2% VOC limit for wipes, both trigger and wipe cleaning products yield an equi valent contribution to VOC emissions. Therefore, providing a higher (yet reduced limit from 4%) VOC limit fo r general purpose cleaners in wipe form would

not result in a lower net VOC reduction in this ca tegory. CSPA requests that ARB consider this issue as part of a 15-day notice subse quent to adoption of the regulation.

b. CSPA urges ARB to create a narrowly-de fined product subcategory for SpecialPurpose Floor Cleaners

.

CSPA urges that a new VOC limit for non-aeroso l Special-Purpose Floor Cleaners (SPFCs) be established that is separate from the category of General Purpose Cleaners. We are willing to accept the 0.5% VOC limit for the vast majority of the products currently defined as GPCs if a new specialty cleaner category is created for Special-Purpose Floor Cleaner with a 3% VOC limit. CSPA’s proposal is aimed at achieving maximum reductions while maintaining the safety and efficacy of these cleaning products, ma ny of which are antimicrobial products.

This change is needed to assure that these t ypes of spray-and-wipe products can be formulated without compromising walkway safety. This is es pecially important due to the fact that older consumers are finding that this t ype of cleaning system is far eas ier to accomplish for consumers without the physical abilities necessary for standard m op-and-bucket floor cleaners.

This new subcategory would be listed in th e Section 94509 Table of Standards as follows:

Product Category VOC Standard Effective Date Special-Purpose Floor Cleaner 3% Dec. 31, 2012

The following modified definitions also would be needed in Section 94508:

“General Purpose Cleaner” means a genera l purpose cleaning product labeled to clean for use on a variety of hard surfaces, incl uding small appliances. “General Purpose Cleaner” includes, but is not limited to, products designed or labeled for general floor cleaning, kitchen, countertop, or sink cleaning, and cleaners de signed or labeled to be used on a variety of hard surfaces such as stovetops, cooktops, or microwaves. “General Purpose Cleaner” does not include “Special-Purpose Floor Cleaner.”

2 Calculation based on the market share of tri gger cleaning products as being approximately twice that of wipes – 2 year US Household Penetration (w/e 8/7/10) Neilson

.CSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 4 of 19

“Special-Purpose Floor Cleaner” means a clean ing product labeled exclusively for use in being applied to hard-surface flooring and wipe d off without transfer of soil to a liquid reservoir. “Special-Purpose Floor Cleaner ” does not include "Floor Maintenance Product," "Floor Polish or Wax" "Floor Wa x Stripper," "Spray Buff Product," or “Wood

Cleaner.”

The technical and scientific reasons for higher VOCs in this category have been outlined in detail by a CSPA member company that will be submitting comments separately. We therefore urge ARB to address this issue further in a 15-day not ice subsequent to adoptio n of this regulation.

2. General Purpose Degreaser (non-aerosol)

This category of products must be formulated to remove a broad spectrum of soils and substrates. Consequently, it will be very difficult for manufacturers to develop new product formulations that will comply with ARB’s propos al to establish a 0.5% VOC limit. The difficult research and development task is further compounded by the great number and diversity of products included in this category ( e.g ., ready-to-use pump sprays, wipes, liq uids with dilutions, liquids without dilutions).

Although the 0.5% VOC limit poses significant ch allenges, CSPA member companies are not opposing the new VOC limit and co mmit to conduct active research and development efforts necessary to comply with this very aggressive VOC content of the products while maintaining the requisite level of product efficacy.

3. Glass Cleaner (Non-Aerosol )

This broad category of products serves many distinct and separate functions for a wide variety of household, institutional, commercial and industria l users. The ARB’s proposed 3% VOC limit poses a substantial challenge for product manufacturers. This re vised proposed limit constitutes a 25% reduction in the currently applicable regulatory limit of 4%, which had already proven difficult to reach for products aimed at rem oving difficult soils and heavy soil buildup without streaking or haze.

Product manufacturers will face a par ticularly difficult challenge to reformulate glass cleaners used in automobiles since these products must remove: (1) grime caused by the off-gassing from the interior of motor vehicles, and (2) insect re sidue and other grime that may be difficult to remove from the exterior windshield. Impaired visibility poses a substantial safety risk to drivers; this problem is exacerbated by the glare of morning and evening sunlight.

Notwithstanding this significant additional re duction in the VOC cont ent for this product category, CSPA member companies commit to e xpend the amount of mone y to conduct the extensive research, development and engineer ing efforts necessary to ensure that the reformulated product: (1) achieve efficient cl eaning, (2) minimize streaking, and (3) minimize residual compounds that remain on the glass that attract grime th at causes increased hazing and more frequent need for cleaning.CSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 5 of 19

4. Oven or Grill Cleaners (aerosol and non-aerosol)

ARB’s proposed VOC limits for the Oven or Gril l Cleaner product categori es are reasonable and necessary. The proposed revisions to the VOC lim its, effective date, and definitions for this product category are needed to assure that produ cts used to remove soils on high temperature

surfaces are safe and effective for consumers. Thus, CSPA supports the proposed changes for this product category.

5. Spot Remover – Dry Clean Only Products

CSPA member companies do not oppose ARB’s propos al to include spot remover products used on dry clean only fabrics into the currently re gulated “Spot Remover” category. In addition, CSPA does not oppose the ARB’s proposed action to extend the existing prohibition on the use of perchloroethylene, methylene chloride and trichlor oethylene for the Spot Remover category to newly added products (e ffective Dec. 31, 2012).

6. Silicone-based Multi-purpose Lubricants

CSPA member companies do not oppose ARB’s propos al to ban the use of perchloroethylene, methylene chloride and trichloroe thylene in this product category.

7. Special-purpose Lubricants (Aerosol and Non-aerosol)

CSPA continues to strongly believe that the 277 non-aerosol products and the 201 aerosol products that would be include d in the proposed “Special- purpose Lubricants” category

constitute too broad and diverse a range of products for a single VOC limit. Specifically, ARB’s proposed definition would include dozens of di fferent types of products — including lithium greases, moly greases, Teflon-based, cutting oils, an ti-seize, chain and cable, gear, gun oil, etc. All of these products have different uses for different consumer s and different VOC requirements; they do not fit into a single “one si ze fits all” category with one regulatory limit.

In addition, the 2012 effective da te proposed does not provide ade quate time for reformulation of hundreds of products. We therefore are urging that any new VOC limits in this area have effective dates of December 31, 2013, to be cons istent with the previously adopted new VOC limit for Multi-Purpose Lubricants.

a. CSPA urges that ARB instead create four specifically defined lubricant categories and provide feasible VOC limits and effective dates

.

After reviewing ARB’s data summary for this product category, CSPA members would not oppose VOC limits and effective dates for the following narrowly-defin ed subcategories:

Category Form VOC Limit (Effective Date)

Anti-Seize Lubricant Aerosol

Non-Aerosol 40% (Dec. 31, 2013) 3% (Dec. 31, 2013)

Cutting and Tapping Oil Aerosol

Non-Aerosol 25% (Dec. 31, 2013) 3% (Dec. 31, 2013)CSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 6 of 19

Category Form VOC Limit (Effective Date)

Gear, Chain and Wire Lubricant Aerosol

Non-Aerosol 25% (Dec. 31, 2013) 3% (Dec. 31, 2013)

Rust Preventive or Rust Control

Lubricant Aerosol

Non-Aerosol 25% (Dec. 31, 2013) 3% (Dec. 31, 2013)

These new categories would be defined in Section 94508 as follows:

“Anti-Seize Lubricant” means any lubricant specifically designed or labeled for antiseizing applications that include prevention of parts seizure and easy of assembly and disassembly applications. “A nti-Seize Lubricant” may include food grade lubricants.

“Anti-Seize Lubricant” does not include “Cutting and Tapping Oil,” “Gear, Chain and Wire Lubricant,” “Multi-purpose Lubri cant,” “Multi-purpos e Dry Lubricant,” “Penetrant,” or “Silicone-bas ed Multi-Purpose Lubricant.”

“Cutting and Tapping Oil” means any lubrican t specifically designed or labeled for use in metalworking operations that include dri lling, cutting and tappi ng metals. “Cutting and Tapping Oil” may include food grade lubr icants. “Cutting and Tapping Oil” does not include “Anti-Seize Lubricant,” “Gear, Ch ain and Wire Lubri cant,” “Multi-purpose Lubricant,” “Multi-purpose Dry Lubricant, ” “Penetrant,” or “Silicone-based MultiPurpose Lubricant.”

“Gear, Chain and Wire Lubricant” means any lubricant specifically designed or labeled for use on gears, chains and wire ropes. “Gear, Chain and Wire Lubricant” may include food grade lubricants. “Gear, Chain and Wire Lubricant” does not include “Anti-Seize Lubricant,” “Cutting and Tappi ng Oil,” “Multi-purpose Lubr icant,” “Multi-purpose Dry Lubricant,” “Penetrant,” or “Silic one-based Multi-Purpose Lubricant.”

“Gun Oil/Lubricant” means a product designed and labeled exclusively for the lubrication of firearms and/or the protecti on of firearm surfaces.” Gun Oil/Lubricants may also reduce friction, heat and wear between moving parts, and/or displace moisture.

“Rust Preventive or Rust Control Lubricant” means any lubricant specifically designed or labeled primarily for the prevention or control of rust. “Rust Preventive or Rust Control Lubricant” may include food grade lubrican ts. “Rust Preventive or Rust Control Lubricant” does not include products used exclusively on firearms, mold release products, “Anti-Seize Lubri cant,” “Multi-purpos e Lubricant,” “Multi-purpose Dry Lubricant,” “Penetrant,” or “Silic one-based Multi-Purpose Lubricant.”

CSPA believes that this approach will result in emission reductions equal or greater than those estimates for the limits proposed by ARB, wh ile providing clearer de finitions and less uncertainly regarding what produc ts are subject to what limits. The proposal, in conjunction with existing definitions, would clarify that the following subcategories of lubricants are not regulated: Industrial-Use Only (not Consumer Pr oducts), Special-Purpose Silicone Lubricant,CSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 7 of 19

Gun Oil, and Special-Purpose Dry Lubricants. It would also clarify th at Food Grade products from the 2006 Survey are subject to regulation in these categories.

In addition, we believe that some of the products reported as Ot her Special Purpose Lubricants would fit the definitions above, including some that are Multi-Purpose Lubricants. Many of the products classified as SPLs in the 2006 Survey summaries are already covered by adopted VOC limits for Multi-Purpose Lubricants, Penetrants and other existing re gulated categories. A few of the products are for Industrial Us e Only. Of the remaining products, a few fall into the four SPL subcategories with limits to be adopted, a few fall into SPL categories suggested for deferment and a small portion fall into undefined categories.

CSPA is willing to work with ARB staff to dete rmine the specific reductions that our proposal will obtain, but we are confident that additional reductions can be credited. We therefore urge ARB address this issue further in a 15-day notic e subsequent to adopti on of this regulation.

b. There is a legitimate technical evidence to justify a 40% VOC limit for the aerosol

form of Anti-Seize Lubricants

.

Aerosol anti-seize compounds generally consist of five major components – grease, graphite flakes, soft metal particles such as copper and aluminum, solvents and propellant. The composition of the first three components is usually the same as for a non-aerosol version of the product. In order to produce a properly f unctioning aerosol versi on, the compound must be miscible with and thinned with an appropriate solvent that allows for proper packaging. The compound is dispensed from the aerosol by the ac tion of an appropriate amount of propellant that provides additional viscosit y reduction and proper delivery characteristics. Addition of LVP solvents is not an option in this category.

In order for the compound to function properly af ter delivery, the dispen sed product must return to its original grease state as rapidly as possible. This requires the us e of a fast evaporating thinning solvent. Although acetone is a fast ev aporating VOC-exempt solvent, it cannot be used in large amounts because it is not miscible wi th the petroleum-based greases that are used, causing them to coagulate and come out of solu tion. Slower evaporating solvents prevent the recovery of the grease by maintaining the dilute d form. LVP-VOC solvents are not suitable for

dilution for this reason.

Effective anti-seize lubricant is essential to the operation and maintenance of numerous types of equipment in commercial as well as industrial op erations. Effective application of anti-seize

lubricant is critical on threaded parts to prevent thread galling that can lead to the parts seizing and being essentially cold-welded together. Failure of these app lications can lead to expensive down-time and equipment losses. Aerosol anti-s eize lubricants are needed for applications

where these threads are difficult to reach with non-spray products.

Based on these considerations, the maximum allowed VOC content for Anti-Seize Compound. Aerosol cannot be less than 40%. These produc ts play an important role in equipment maintenance and must be applied and perform properly to prevent equipment damage and downtime. We therefore urge ARB to seek to have this issue addressed further in a 15-day notice subsequent to adop tion of this regulation.CSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 8 of 19

c. There is a legitimate need for the use of perchloroethylene to formulate Gear, Chain and Wire Lubricant and Cutting and Tapping Oil

.

CSPA will support a chlorinated solvent prohib ition for “Anti-Seize Lubricant” and “Rust Preventive or Rust Control Lubricant,” but not for “Gear, Chain and Wire Lubricant” and “Cutting and Tapping Oil” where perchloroethylene is needed in some products that require the solvency, volatility, viscosity and/ or low flammability that can onl y be obtained from chlorinated solvents. It is important to understand that although most such chlorinated-solvent products are not labeled as flammable, they still require la bel warnings that avoid container overheating or hazardous combustion products.

Product formulators have made a concerted effort to eliminate the use of chlorinated solvents from their products. However, as a practical matte r, there are limited situations where the use of this compound should not be eliminated. CSPA is willing to work with ARB to clearly define

where chlorinated solvents are n eeded in these two categories of lubricants and which products therefore must be excluded from any prohibition. We therefore urge ARB to seek to have this issue addressed further in a 15-day notice s ubsequent to adoption of this regulation.

d. CSPA suggests that the clarity of the regulation would be improved if all lubricant categories are grouped together.

In other areas of the regulation, ARB has made significant improvements to the clarity of the various provisions by grouping together products and provisions so that all similar provisions, added over many years and rulemakings, can be more clearly identified. We believe that this should now be done with Lubricants, which are regulated in categories whose definitions and standards are scattered throughout the regulation. We suggest that ARB consider listing all Lubricants together in the Table of Standards. We therefore urge ARB to seek to have this issue

addressed further in a 15-d ay notice subsequent to a doption of this regulation.

8. Heavy-duty Hand Cleaner or Soap

Heavy-Duty Hand Cleaners serve important functions for many consumers and workers who

come into contact with difficult to remove soils that are often can have dermatological impacts if not fully removed. To remove some of these soils requires significant amounts of VOC solvents, especially where adequate water is not available to assist in removal of the emulsified soils.

It is also important to note th at much of the VOC content of th ese products currently consists of

sustainable bio-based citrus extr acts. We suggest that ARB shoul d encourage the use of renewable

and sustainable bio-based mate rials in these products. Bio-based materials are made by photosynthesis from carbon dioxide sequestered from the atmosphe re and degrade into carbon dioxide and water, and therefore do not contribute to net carbon emissions or global warming.

Renewable bio-based materials usable in these products are not listed as HAPs, TACs or on the Proposition 65 lists, and generally ha ve very positive profiles for hea lth and safety of humans and the environment. We believe that encouraging bioba sed materials is very consistent with the goals of the California Environmental Quality Act CEQA to minimize the other environmental and health impacts of regulations.CSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 9 of 19

CSPA believes that an approach is needed that will allow for effective Heavy-Duty Hand Cleaners while reducing VOCs in a manner th at does not inhibit th e use of renewable and sustainable biobased VOC materials or increase the use of materials that incr ease net carbon emissions.

CSPA therefore is willing to accept the 1% li mit proposed for “Heavy-Duty Hand Cleaner or Soap” if a 5% VOC limit is allowed for “Sp ecial-Purpose Heavy-duty Ha nd Cleaner” defined as those labeled exclusively for removal of a few sp ecific hard-to-remove soils where water is not available for rinsing. We therefore ask the A RB to consider the following changes to the proposed rule

ARB should add or modify the follo wing definitions in Section 94508:

“Special-Purpose Heavy-Duty Hand Cleaner ” means a product designed and labeled exclusively to remove specific soils such as adhesives, asphalt, creosote, PCB’s, tar, tree sap, or soot from the hand without necessi tating the use of water. “Special-Purpose Heavy-duty Hand Cleaner” does not include pr escription drug products, “Antimicrobial Hand or Body Cleaner or Soap,” “Astring ent/Toner,” “Facial Cleaner or Soap,” “General-use Hand or Body Cleaner or Soap,” “Medicated Astringent/Medicated Toner” or “Rubbing Alcohol.”

"Heavy-Duty Hand Cleaner or Soap" means a product designed to clean or remove a variety of more difficult dirt a nd soils such as oil, grease, grime, shellac, putty, printer’s ink, paint, graphite, or cement, from the ha nd with or without the use of water. "Heavyduty Hand Cleaner or Soap" does not include prescription drug products, "Antimicrobial Hand or Body Cleaner or Soap," "Astringent/Ton er," "Facial Cleaner or Soap," "Generaluse Hand or Body Cleaner or Soap," “Special-Purpose Heavy-Duty Hand Cleaner,” "Medicated Astringent/Medicated Toner" or "Rubbing Alcohol."

"General-use Hand or Body Cleaner or Soap" means a cleaner or soap designed to be used routinely on the skin to clean or remove typical or common dirt and soils. "Generaluse Hand or Body Cleaner or Soap" includes, but is not limited to, hand or body washes, dual-purpose shampoo-body cleaners, shower or bath gels, and moisturizing cleaners or soaps. "General-use Hand or Body Cleaner or Soap" does not include prescription drug products, "Antimicrobial Hand or Body Cleaner or Soap," "Astringent/Toner," "Facial Cleaner or Soap," "Hand Dishwashing Deterg ent" (including antimic robial), "Medicated Astringent/Medicated T oner," or "Rubbing Alcohol."

ARB should add the following product categories, VOC limits and effective dates to the

Section 94509 Table of Standards:

Product Category VOC Standard Effective Date Special-Purpose Heavy-Duty Hand Cleaner 5% Dec. 31, 2013 Heavy-Duty Hand Cleaner or Soap 1% Dec. 31, 2013

The soils included in the “Special-Purpose Heavy- Duty Hand Cleaner” definition are the primary soils encountered by safety, military and repair pers onnel working out of mobile units in the fieldCSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 10 of 19

without access to running water. This approach is also similar to the approach used by Green Seal, where they are divided as follows:

• GS 41 A (Institutional Hand Cleaners): 1% VOC maximum

• GS 41 B (Industrial Heavy Duty Hand Cleaners): 8% VOC maximum

CSPA believes that the approach proposed by C SPA will allow for effective Heavy-Duty Hand Cleaners while also reducing VOCs. It would also do so in a manner that does not unduly inhibit the use of renewable and sustainable, bio-based materials, or increase the use of nonrenewable materials that increase net carbon emissions, whic h we believe are important goals for ARB as well as our industry.

CSPA has surveyed major marketers of these pro ducts to determine which would be subject to the 1% limit and which to the 5% limit per this proposal. The survey covered 126 products, of which 15 would be classified as “Special-Purpos e Heavy-Duty Hand Cleane rs” as defined above. A copy of the specific survey resu lts can be provided to ARB to allow emission reductions to be calculated for these categories and limits. We th erefore urge ARB to seek to have this issue

addressed further in a 15-d ay notice subsequent to a doption of this regulation.

9. Flying Bug Insecticide (Aerosol)

Based upon the technical data submitted to ARB by CSPA members, there is ample evidence to support the need to maintain an adequate amount of VOC ingredients for ensuring the efficacy of this important public health product. The proposed 20% VOC limit constitutes a significant reduction from the current regulatory limit. Adequa te levels of propellants are needed in these products to allow the uniformly small particle size necessary for efficacy while minimizing active ingredient levels. Notwithstanding this sign ificant reduction in the VOC content for this product category, CSPA member companies comm it to expend the considerable amount of money to conduct the extensive research, develo pment and engineering efforts necessary to ensure that the reformulated products are effect ive while maintaining the low active ingredient levels in current products.

This product category is subject to regulation under the Federal Insect icide, Fungicide, and Rodenticide Act (FIFRA) 3 and the California Food and Agricultural Code. 4 Under both federal and state law, any new formulati on of FIFRA-regulated products must be reviewed and approval by both the U.S. Environmental Protection Agency and the California Department of Pesticide Regulation before the product may be offered for sale . In addition to reformulation, this need for data generation, review and registration by bot h the federal and state agencies imposes a significant additional – and time-consuming – requi rement on product manufacturers. Therefore, the December 31, 2013, effective date for this product category is both reasona ble and necessary.

10. Wasp or Hornet Insecticide (Aerosol)

ARB’s proposal to set a 10% VOC limit for this important public health product presents a significant technological challenge for manufactur ers. Notwithstanding these challenges, CSPA member companies commit to expend the consider able amount of money needed to conduct the

3 See generally 7 U.S.C. §§ 136-136(y).

4 Cal. Food & Agric. Code §11501.CSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 11 of 19

extensive research, development and engineer ing efforts necessary to ensure that the reformulated product remains effective and afford able to consumers – and especially for lowincome households.

This product is also subject to regulation under FIFRA and the California Food and Agricultural Code. In addition to the time-consuming review and registration process there is an additional

time constraint factor that furt her complicates manufact urers’ efforts to reformulate this product category: the window of opportunity to test this product category is limited to summer months of July and August (the two months in which wasp s and hornets are most active). Therefore, the December 31, 2013, effective date for this product category is both reasonable and necessary.

11. Furniture Maintenance Product (Aerosol )

ARB’s proposal to set a 12% VOC limit for th is product category constitutes a significant reduction of the currently applic able regulatory standard. C PSA member companies commit to work diligently to meet this ambitious challenge of reformulating this product category to meet ARB’s stringent new VOC limit while ensuring that products will meet the needs of consumers who rely upon these products to main tain their expensive furniture.

Based upon the technical data presented to ARB, it is abundantly clear that extra time is needed to accomplish reformulations and packaging/sp ray technology changes, and product testing, including the consumer testing and storage and stability testing require d for these types of aerosol products. Thus, the proposed 2013 effec tive date for the revised VOC limit is both reasonable and necessary.

12. Metal Polish / Cleanser (A erosol and Non-aerosol)

This broadly defined category of products perf orms many separate and distinct functions on different metal substrates for a variety of house hold, institutional, and co mmercial users. ARB’s proposal to establish a 15% VOC limit for the aerosol form and a 3% VOC limit for the nonaerosol form of this product category poses significant technol ogical challenges for manufacturers. Despite these challenges, CSPA member companies commit to expend the time and monetary resources to conduct research, de velopment and engineering efforts need to reformulate our products to meet ARB’s very st ringent VOC limits for both forms of this product

category.

In addition, CSPA member companies do not oppose ARB’s proposal to ban the use of perchloroethylene, methylene chloride and tr ichloroethylene in this product category.

B. Comments on ARB Staff’s Proposals for Other Regulatory Requirements

1. CSPA Generally Supports the Proposed Revi sion to the Most Restrictive Limit

Provision

.

ARB’s proposed revision to 17 CCR § 94512(a)(3) pr ovides clear regulatory language to address situations in which product category definitions may have the unintended effect of excluding each other (thus potentially causing the product to be outside the scope of ARB’s statewideCSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 12 of 19

regulation). CSPA generally supports the “b right line” guidance provided by this proposed revision because this is the type of clarity needed for manufacturers to ensure that their products comply with the appropriate and applicable VOC limits.

However, CSPA believes that ARB may have unin tentionally removed an important text of the existing regulation stating that th is provision does not apply to certain Disinfectant/Sanitizer products. Thus, CSPA urges ARB to restore th e following text from the existing regulation:

Notwithstanding the foregoing above, th is provision does not apply to

“Disinfectant”/”Sanitizer” products labeled as “Bat hroom and Tile Cleaners,” “Glass Cleaners,” “General Purpose Clean ers,” “Toilet/Urinal Care Products,” “Metal Polishes,” “Carpet Cleaners,” or “Fabric Refreshers” that may also make disinfecting/sanitizing or anti-mic robial claims on the label.

Unless this language is restored, the adop tion of the amended language may have the

unintentional immediate effect of changing the regulatory status of many products that make disinfection/sanitization claims, resulting in those products no longer being in compliance with current VOC limits. We urge ARB to address this issue in a subsequent 15-day notice. CSPA also requests the opportunity to work with ARB staff in the future to identify and remedy any additional problems related to the proposed revision to 17 CCR § 94512(a)(3).

2. ARB’s New Tables Set Forth at 17 CCR §§ 94509(m)(1)-(2) and § 94509 (n)(1) Enhance the Overall Clarity of the Regulation

.

CPSA generally supports ARB’s decision to deve lop three tables to summarize applicable

restrictions on the use of certain chemical compounds in specifically enumerated product categories. Under the current regulation these prohibitions are spread out in seven different subsections of 17 CCR § 94509. At a minimum, pres enting pertinent information in three tables eliminates duplicative la nguage in the seven subsections contai ned in the current regulation. As a practical matter, this is the type of information that is more clearly pres ented in a table format rather than in formal regulatory language.

We believe, however, that an inadvertent error was made in deleting subsection 94509(q)(5) which exempts some Penetrants from the require ments of that section. We support this being corrected in a 15-day noti ce subsequent to adoption.

3. CSPA Questions But Does Not Oppose the Prohibition of Alkylphenol Ethoxylate Surfactants in Certain Categories

Proposed Section 94509(m)(3) would prohibit the use of alkylphenol ethoxylate (APE) surfactants in five categories of products for which revised VOC limits are proposed. Since

these and other surfactants are re ported in the 2006 Survey as gr ouped organics, adequate data do not exist to determine to what degree these surf actants are used in the categories of products. Although we do not believe that th is prohibition is justified base d on the environmental impacts of the low levels of use of APEs in these pr oducts, and know of no reason to believe that any

additional APEs would be used in reformulati ng these products to meet the lower VOC limits, CSPA will not oppose the addition of this prohibition.CSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 13 of 19

4. CSPA Supports Appropriat e Revisions to Method 310

Two modifications are being proposed to A RB Method 310, the first to facilitate the determination of aromatic compound content in Multi-Purpose Solvents and Paint Thinners, and the second to determine compliance with the Fabric Softener Single Use Dryer Product VOC

limit.

Regarding the proposed addition of test methods for aromatic cont ent, there are many analytical methods that may be use for analyzing the aroma tic content in hydrocarbon solvents, but there is no one single method that can be used to conduct an accurate analysis. We understand that this was described more completely in a te lephone conversation between ARB staff and representatives of a CS PA member company. Moreover, th ere may be confounding factors in some analytical methods. As a threshold matter, the chemist must know which compounds are contained in the product that is being analyzed. Then, the analyt ical chemist must select the method that is most appropriate for measuri ng that those specific compounds. For example a

method used for an LVP would not be appropriate for a non-LVP.

Thus, CSPA believes that having a list of analyti cal methods is useful, but urges ARB to include

a caveat or disclaimer that care must be take n in determining the most appropriate method or methods to use. In addition, CSPA believes that the methods listed by ARB and any other method that can be demonstrated to be equivalent to the listed methods sh ould be allowed to be used. This is particularly true for the ultrav iolet absorption method that is commonly used in industry for detecting aromatic c ontent. Attached please find a matrix assessing the capabilities and limitations of the various analyt ical test methods listed by ARB.

As it relates to the addition on calculation of VOC content of dryer sheets, CSPA supports the position of the American Cleaning Institute, which will be filing comments in this area.

C. Comments on Other Sections of th e Initial Statement of Reasons

1. ARB Overstates the Degree to Which It Has Been Established that This Regulation is Necessary to Meet Ozone Standards.

In the Initial Statement of Reasons (ISOR), it is noted that the reductions from this rulemaking are part of the State Implementation Plan (SIP) adopted by ARB in 2007, and would be the “thirdincrement toward fulfilling the commitment for VOC reductions for consumer products” (page I4). It is further stated that, “Because Califor nia has unique air quality problems, reducing VOC emissions from all categories, including consum er products, to the maximum extend feasible, is necessary to attain the federal and state ambien t air quality standard for ozone” (page I-5). In addition, it is noted that future population growth are projected to cause increased emissions from consumer products (page IV-25).

Later in the ISOR, ARB states:

Because significant further VOC emissions reduc tions are necessary to attain the national and State ozone standards, the reductions fro m the amendments proposed in this report are therefore “necessary” within the meaning of section 41712 of the Health and Safety Code. In addition, section 41712(b)(1) of the Health and Safety Code provides that the “necessity” of a regulation is to be evalua ted in terms of both the State and federal

standards.CSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 14 of 19

The applicable State and federal laws show that both the U.S. Congress and the California Legislature intended progress toward clean air be made as quickly as possible. The CCAA specifically declares that it is the in tent of the Legislature that the State air quality standards be achieved “...by the earliest practicable date...” (See Health Technical Support Document Chapter V – 40 and Safe ty Code, sections 4091 0 and 40913(a); see also the uncodified section 1(b)(2) of the Act (Stats. 1988, Chapter 1568)). A similar intent is expressed in the federal Clean Air Ac t, which declares that the federal air quality standards are to be achieved “...as expeditious ly as practicable...” (See sections 172(a)(2), 181(a), and 188(c) of the federal Clean Air Ac t). For all of the reasons described above, the proposed amendments are “necessary” within the meaning of section 41712 of the Health and Safety Code.

CSPA disagrees that these arguments are adequa te to demonstrate that this regulation is “necessary to attain the federal and state ambien t air quality standard fo r ozone” as required by Section 41712(b)(1) of the Health and Safety Code. Although it is true that further VOC reductions for consumer products were included in the California SIP adopted in 2007 (but not yet approved by EPA), there was no attempt in the SIP process to determine whether or not each of the reduction goals set for various emission cat egories were necessary to attain the ozone standard. The process by which the SIP goals were designated involved essentially reducing all

VOC emission sources and all NOx emission sour ces until modeling showed attainment of the standard at all locations in the modeled region. Bu t different sources have very different impacts on ozone formation per mass emissions, due to va rying photochemical reactivity and geographic

differences in where the emissions occur. There were no subsequent sensitivity runs to determine whether it was necessary to reduce all of the sources by those targeted amounts to

reach attainment. CSPA believes that sensitivity runs must be included in SIP development if ARB is to meet its requirement to demonstrate that the reduction goal for consumer products is “necessary.”

Subsequent to the 1994 California SIP revisi on, CSPA and other consumer product industry associations conducted a study to assess the sensitivity of ozone in the South Coast and

Sacramento air basins to c onsumer product VOC emissions. Our 1997 attainment remodeling study was conducted under 2010 attainment conditions that remained highly sensitive to overall VOC emissions. The results of that study de monstrated that even under highly VOC-limited

conditions where ozone formati on is highly sensitive to overa ll VOC levels, ozone formation

was not at all sensitive to consumer product VOC emissions.

The attainment demonstration modeling for th e 2007 SIP and South Coast AQMP, on the other hand, was under atmospheric conditions that are far more NOx-limited, and far less sensitive to

overall VOC emissions. We therefore had r eason to expect that consumer product VOC emissions should have even less relative impact on ozone attainment in this 2023 attainment

scenario. To determine whether this was indeed the case, CSPA contract ed in 2007 with Sierra

Research and Environ to conduct a remodeli ng study, co-funded by nine national consumer product industry associations, to determine the ozone sensi tivity of consumer product VOC emissions in the South Coast in 2023, and dete rmine what level of emission reductions might actually be necessary. The remodeling study was co mpleted along with the final report from the study, “Assessment of the Need for Long-Term Re duction in Consumer Product Emissions in the

South Coast Air Basin.” 5

5 Sierra Research Repot No. SR2007-09-03, September 12, 2007.CSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 15 of 19

The results of the Sierra Research study clearly demonstrated that ozone attainment status in the

South Coast district would not be impacted in 2023 if no further reductions in consumer product

VOC emissions are made after 2014. The data show that the 50 tons per day of additional statewide consumer products VOC emissions re ductions suggested in the South Coast AQMP would have no impact on ozone attainment anywhe re in the South Coast. These VOC emission reductions would likely cost the consumer products industry more than $1 billion just to determine their feasibility, despite not be ing necessary for ozone attainment.

The modeling data supplied by South Coast to Environ for their modeling runs also provided important information regarding the District consumer product m easures proposed in the AQMP as CTS-01, CTS-03 AND CTS-04, which are listed as seeking 1.9, 2.1 and 5.8 tons per day VOC reductions in South Coast, respectively, and appear to be included by the District as “backstop” measures to be implemented only if the sim ilar state consumer product measures are not implemented. Environ and Sierra Research indeed found that two of these three measures were

not used to make additional reductions in the co nsumer products inventory in the ozone attainment

demonstration for 2023. The reduction commitment for CTS-01 is made to other emissions categories and no reduction was made to cons umer products emissions. The reduction

commitment for CTS-04 was not used to reduce a ny emissions category. Only the reduction from

CTS-03 was used in the District’s attainment runs.

CSPA continues to believe that the results of these types of s ource-sensitivity studies provide important information to support th e development of effective ozone attainment strategies. It is important that the control measures in the SIP be focused primarily on those emissions sources (both VOCs and NOx) that play a significant role in ozone non-attainment in the South Coast

and other nonattainment districts. The need to carefully consider the relative ozone impacts of various emission sources also prov ides further reasons for the a llocation of emissions reductions in the “Black Box” to remain unspecified in this SIP revision. This would allow further data to be developed to show what emissions sources and reductions are actual ly necessary for ozone

attainment.

2. CSPA Continues to Disagree with ARB’s Outlined Interpretations of the Terms Technological and Commercial Feasibility

ARB outlines in the ISOR its interpretation of the key statutory term, “technologically and commercially feasible,” which all VOC limits set for consumer products are required to be (pages III-12 to III-14). CSPA continues to disagree with the interpretation outlined, and believes that the argument presented in the IS OR not only misrepresent s industry’s position, but also posits an extreme interpretation that has se ldom if ever been used by ARB, and should not

be used in the future.

ARB argues that technological and commercial feasibility must be evaluated separately, and that a limit can be established to be technologically feas ible if at least one product in the category is in compliance or the limit can reasonably be met through “additional development efforts.” CSPA continues to disagree that one or a few complying products in a category—products that may be used for different purposes by different consumers—can demonstrate that a VOC limit is feasible for all of the products in a broad category. CSPA even more adamantly disagrees that product technology posited by ARB that has never b een developed or marketed can be deemed to be technologically or co mmercially feasible by ARB.CSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 16 of 19

In interpreting the term “commerci al feasibility,” ARB uses the International Harvester case 6 to argue that all consumer preferen ces do not have to be met as l ong as “basic market demand” is met. The example given relates to glass cleane rs, where products without the smell of ammonia is a consumer preference, and can be used to replace VOC solvents. This example is not only technically incorrect as it relate s to product technology, but also as it relates to CSPA’s position. It is not consumer “preference” that we believe must be maintained for a limit to be considered feasible, but the effectiveness of the product in accomplishing the ta sks for which it is used.

Moreover, CSPA believes that ARB has sought to a ssure the feasibility of its proposed limits and other provisions in a manner more consistent w ith our interpretation of the term technologically and commercially feasible than the interpretation outlined in this ISOR. It is vitally important that ARB continue to do so, a nd not revert to an extreme and unreasonable interpretation that

would result in limits that would not allow effectiv e products in California, and result in loss of consumer benefits, loss of California businesses that rely on effective products, or forcing consumers to substitute other products or material s that may result in high er air quality impacts.

3. CSPA Agrees that Adequate Data Exists for Most If Not All of the Proposed

Provisions

CSPA generally concurs with ARB’s assessmen t that the 2006 Consumer and Commercial Products Survey and other related data collectio n provides adequate data upon which to base the VOC limits proposed in this rule (page V-34). CSPA’s concerns raised in these comments primarily relate to the interpreta tion of that data in establishing technologically and commercially feasible standards. This may not be true, how ever, for all of the provisions being proposed. Alkylphenol ethoxylate surfactants, for instance, were reported in the 2006 Survey as grouped organics along with other non-sp eciated LVPs, and the survey cannot provide adequate data on the extent of their use, or the costs that might be incurred by the proposed prohibition.

4. CSPA Generally Concurs that ARB’s Economic Impact Assessment for this Proposal is

Performed Consistent With Other Rulema kings But Questions Some Cost Estimates

.

The proposed regulation would require reform ulation of 1,467 products (see page V-37) and estimates total industry costs of approximate ly $50 million (annual costs of $5 million over 10 years) (see page VIII-109). This works out to $34,000 per product. While many product reformulations proposed to be required can be accomplished for this cost, many others will require up to ten times as much to reformulate. In addition, as VOC limits are further and further reduced, it becomes more and more likely that in itial reformulations will not prove commercially feasible, requiring further costs, or even loss of product markets.

Among the most questionable assumptions and cost estimates the tables seen in Chapter VIII were the following:

• Zero recurring costs for more expensive ingredients in General Purpose Cleaners. It appears that this is based on the difficult-t o-explain assumption that these products do not contain any surfactants, and will comply by reducing the use of LVP solvent by two percent and increasing the use of LVP glycol ethers by 0.5% ( see Appendix D-3). The ingredients listed for existi ng products do not conform with any existing products (or the

6 International Harvester Company v. Ruckelshaus , 478 F. 2d 615 (D.C. Cir. 1973).CSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 17 of 19

category as a whole) and the changes in ingr edients postulated for complying make even

less sense.

• Low-Estimate reformulation costs for refo rmulating insecticides of $1,641 for Flying Bug and $298 for Wasp or Hornet. These cost s are at least one and possibly two orders of magnitude low. The regulatory paperwork alone far exceeds these estimates for these FIFRA-regulated products.

• Zero recurring costs for more expensive ingr edients for Flying Bug Insecticide that is

based on reducing the level of surfacta nts from 2% to 1%, reducing LVP solvents from 9% to 8%, and reducing LVP Glycol Ether from 5% to 4%. We know of no sensible reason to predict that VOC reductions will be made in a manner that reduces costly nonVOC ingredients.

• The assumption that the already underestima ted low-estimate of nonrecurring costs is incurred per company instead of per pr oduct in calculating to tal industry costs ( see Table VIII-3). There is no possible economy of scal e that would allow a company to reformulate their entire product line for a few hundred dollars.

• The assumption that pesticide and disinf ectant (FIFRA-registered) products barely exceed other household products in low-es timate of nonrecurring product development costs (Appendix E, Table E-1) and in the high -estimate cost are ac tually cost less to reformulate (Appendix E, Table E-2). In the categories regulated, FIFRA products will always cost significantly more to reformulate. This explains some of the anomalous cost

estimates noted above.

We would also note that assumption that “we do not expect manufacturers to sell and distribute California-only products” may become less valid in the future. In a rece nt survey of member companies relating to “reasonably prudent precau tions” taken to avoid non-California products being distributed in the state, CSPA found that a growing percen tage of products are now being formulated for sale outside of California, and pr oducts whose sales are primarily or solely in

California could occur if provisions become too rest rictive for effective produc ts to be sold in the

state.

5. CSPA Supports ARB’s Planned Actions to Clarify the Distinction between General Purpose vs. Specialty Products

.

CSPA supports ARB’s deci sion, as noted in the Init ial Statement of Reasons ( page ES-16 ) to develop an enforcement advisory to provide needed clarity regarding the distinction between “general purpose” or “multi-purpose” products a nd products that are formulated to serve a specific purpose only. It is important to clarify this issue since it could impact the feasibility of some of the limits being considered in thes e 2010 Amendments. CSPA looks forward to working with other interested stakeholders a nd ARB staff on this impor tant clarification.CSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 18 of 19

6. CSPA Supports ARB’s Planned Action to Clarify the Provisions Relating to

“Minimum Recommended Dilution” and “Incidental Use .”

Under the current regulation, th e applicable “minimum recomme nded dilution” requirements do not apply to recommendations fo r the “incidental use of concen trated product to deal with limited special application such as hard-to-remo ve soils or stains.” 17 CCR §§ 94509(b)(1). CSPA supports ARB’s deci sion, as noted in the Init ial Statement of Reasons ( page ES-16 ) , to develop an enforcement advisory to provide needed clarity rega rding this provision. CSPA also looks forward to working with other interested stakeholders and ARB staff on this important

clarification.



### S UMMARY AND 

### C ONCLUSIONS

During this rulemaking process, CSPA worked closely and cooperatively with ARB staff, environmental groups, air districts and various ot her stakeholders as pa rt of the Consumer Products Regulation Workgroup (CPRWG). As a re sult of this open and transparent process, ARB Staff developed and proposed challenging new VOC and GWP limits that will provide significant emission reductions. The ARB Staff should be commended for efforts to conduct a fair and thorough rulemaking process to develop this major regulation.

The proposed new and revised VOC limits and re lated enforcement provisions present very serious and costly reformulating and marketing challenges. CSPA hopes that the proposed VOC limits will prove feasible in the time frames a llowed for compliance. Notwithstanding these significant challenges, CSPA members commit to initiate actions necessa ry to reformulate a broad range of products to meet these challengi ng new VOC limits with the understanding that

ARB staff will address several issues in a 15- day notice subsequent to adoption of this regulation.

CSPA is not opposing in these comments most of new VOC limits and other provisions being proposed as 2010 Amendments to the Consumer Products Regulation. We do, however, ask that a few proposed limits and provisions be deferred in to a 15-day comment period so that we can

continue work with ARB to assure that all provisions are commercia lly and technologically

feasible.

Once again, we expresses our appreciation for the opportunity to comment on the ARB staff’s proposed amendments to California’s very st ringent and comprehensive Consumer Products Regulations. Please contact us any time if you have questions regarding any of the issues raised

in these comments.

Respectfully submitted,

D. Douglas Fratz Joseph T. Yost Vice President, Scientific Director, Strategic Issues Advocacy

& Technical AffairsCSPA Comments on Board Agenda Item # 10-10-7 November 16, 2010 Page 19 of 19

cc: Richard Corey, Chief, Stationary Source Division Janette Brooks, Chief, Air Quality Measur es Branch, Stationary Source Division Carla Takemoto, Manager, Technical Eval uation Section, Stationa ry Source Division Judy Yee, Manager, Implementation Section, Stationary Source Division David Mallory, P.E., Manager, Measures Deve lopment Section, Statio nary Source Division Nicholas Berger, Air Pollution Spec ialist, Air Quality Measures Branch CSPA Air Quality Committee & Task Forces Laurie Nelson, Randlett • Nelson • Madden AssociatesRalph M. Kowalik, Ph. D., ExxonMobil Chemical Company, 4Aug101Assessment of Test Methods to MeasureAromatic Hydrocarbons in Multi-Purpose Solvents and Paint Thinnersfor Inclusion in ARB Method 310Test Method Summary Description Suitable forPurpose(Yes/No/Maybe)Capabilities / LimitationsASTM D 5443 Multi-column GC method thatprovides paraffinic, naphthenic,and aromatic fractions ofhydrocarbon mixtures includingseparation by carbon numberfor the lower carbon numbersMaybe Method covers typical VOC and LVP boilingranges up to 270 oC; non-hydrocarbons (e.g., oxygenated solvents) may co-elute withinhydrocarbon groups and give erroneousresultsASTM D 3257 Single, polar column GCmethod that separates aromatichydrocarbons from nonaromatic hydrocarbons withinmineral spirits rangeMaybe LVP range aliphatic hydrocarbons withboiling points > 235 oC (n-C13) may co-elutewith aromatics and give erroneous results;non-hydrocarbons (e. g., oxygenatedsolvents) may co-elute with aromatics andgive erroneous resultsASTM D 3710 Gas chromatography distillation(GCD) method that separatesgasoline components by boilingrangesNo Method does not separate aromatics fromnon-aromaticsASTM D 3606 2-column GC method thatcollects components lighterthan octane and then uses apolar column to separate andmeasure individual componentconcentrations, in particular,benzene and tolueneNo Method does not measure C8 and higheraromaticsRalph M. Kowalik, Ph. D., ExxonMobil Chemical Company, 4Aug102ASTM D 5580 2-column GC method that splitsoff groups of aliphatic andaromatic species in finishedgasoline via a polar column andback flush and then measuresremaining componentsMaybe Many oxygenated solvents are split off withaliphatic hydrocarbons and do not interfere;aliphatic hydrocarbons C12 and higher mayinterfere with C9 and higher aromaticsEPA 8021(replaces EPA602/8020)General GC method used tomeasure concentrations ofspecific compoundsNo Does not identify all aromatic compoundsthat could be present in multi-purposesolvents and paint thinnersEPA 8015 General GC method used tomeasure concentrations ofspecific compounds or rangesof organics (gasoline rangeorganics, diesel rangeorganics)No Does not separate aromatics from nonaromatics in organic ranges; does notidentify all aromatic compounds that could bepresent in multi-purpose solvents and paintthinnersEPA 8270 General GC/MS method tomeasure concentrations ofspecific semi-volatile organiccompounds (SVOCs)No Does not identify all aromatic compoundsthat could be present in multi-purposesolvents and paint thinners; "in most casesthe method is not appropriate for thequantitation of multi-component analytes"RECOMMENDED METHODAFNOR NF M07-073UV absorption method tomeasure aromatics in heatingfuels and other mainlysaturated hydrocarbonsYes Measures aromatics in the VOC and LVPrange; aliphatic hydrocarbons andoxygenated solvents donot interfere; mayneed to break emulsion products beforeanalyzing; may need to skip acid wash step ifwater and/or oxygenated solvents arepresent; method written in French©2010 ExxonMobil. Use of this information is limited to the specified recipient. While the information is accurate to the bestof our knowledge and belief as of the date compiled, it islimited to the information as specified. Norepresentation or warranty, expressed orimplied, is made regarding the information, or its completeness, merchantability, or fitness for aparticular use. The user is solely responsible for all determinationsregarding use, and we disclaim liability for any loss ordamage that may occur from the use of this information.ExxonMobil does not guarantee typical (or other) values. Test methods are available upon request.