November 16, 2010 via e-mail 

Air Resources Board 

1001 I Street, 23rd Floor 

Sacramento, California 95814 

Attn: Ms. Lori Andreoni 

Manager, Board Administration and Regulations Coordination Unit

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 Board (ARB) on the proposed amendments to the 

state’s comprehensive Consumer Products Regulation.1

 The proposed amendments will add 

and/or modify product category definitions and establish 15 new or lower VOC limits for broad 

categories of consumer products. The proposed new limits on volatile organic compounds 

(VOCs) will result in additional emission reductions of approximately 6.9 tons per day once fully 

effective. CSPA member companies manufacture or market all of the products included in the 

proposed 2010 Amendments. In most cases, CSPA 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 stated in these earlier documents are hereby incorporated by 

express reference in the current comments that we are submitting today. 

CSPA participated as an active member of the ARB’s Consumer Products Regulation 

Workgroup (CPRWG). We commend ARB 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 for 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 identify potential opportunities for 

reductions in the VOC content of consumer products in the hope that these challenging new 

regulatory limits will prove to be technologically and commercially feasible. 

 1

 The text of the proposed amendments to the California 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 17TH STREET, NW, SUITE 300, WASHINGTON, DC 20006    (P) 202.872.8110   (F) 202.872.8114    WWW.CSPA.ORG
CSPA Comments on Board Agenda Item # 10-10-7 

November 16, 2010 

Page 2 of 19 

CSPA member companies take seriously the environmental 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 new technologies necessary to reformulate their 

products to meet the aggressive and technology-forcing VOC limits such as those that will be 

established by this proposed regulation. 

CSPA’s commitment to meet this new challenge is consistent with our member companies’ longstanding efforts to work constructively 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 consumer products to help improve air quality in 

California while maintaining our industry’s ability to supply effective products that consumers 

can rely upon to contribute positively to their health, safety, and quality of life. 

STATEMENT OF INTEREST

CSPA is national trade association representing the interests of approximately 240 companies 

engaged in the manufacture, formulation, distribution and sale of consumer and commercial 

products that help household and institutional customers create cleaner and healthier 

environments. CSPA member companies’ products 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 performance 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 marketed nationally. Through its product stewardship 

program Product Care® and scientific endeavors, CSPA provides its members a platform to 

effectively address issues regarding the health, safety, sustainability and environmental impacts 

of their products. 

COMMENTS

A. Comments on Proposals for Specific Product Categories 

1. General Purpose Cleaners (non-aerosol)

The proposed new VOC limit, if adopted by the Board, 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 products in this broad category pushes almost to 

the breaking-point the envelope of technological and commercial feasibility. This limit is very 

difficult for spray-and-wipe surface cleaners and wipes, non-aerosol product forms in this 

category that do not utilize large quantities of (often 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 limit for two product 

subcategories – General-purpose Cleaners in wipe form and Special-purpose Floor Cleaners. 

a. CSPA urges ARB to consider adopting 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 trigger form of product to clean a given surface area 

than is used when cleaning the same surface area with a wipe product. 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 equivalent contribution to VOC emissions. Therefore, providing a 

higher (yet reduced limit from 4%) VOC limit for general purpose cleaners in wipe form would 

not result in a lower net VOC reduction in this category. CSPA requests that ARB consider this 

issue as part of a 15-day notice subsequent to adoption of the regulation. 

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

CSPA urges that a new VOC limit for non-aerosol 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, many of which are antimicrobial products. 

This change is needed to assure that these types of spray-and-wipe products can be formulated 

without compromising walkway safety. This is especially important due to the fact that older 

consumers are finding that this type of cleaning system is far easier to accomplish for consumers 

without the physical abilities necessary for standard mop-and-bucket floor cleaners. 

This new subcategory would be listed in the 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 general purpose cleaning product labeled to clean 

for use on a variety of hard surfaces, including 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 designed 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 trigger 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 cleaning product labeled exclusively for use in 

being applied to hard-surface flooring and wiped off without transfer of soil to a liquid 

reservoir. “Special-Purpose Floor Cleaner” does not include "Floor Maintenance 

Product," "Floor Polish or Wax" "Floor Wax 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 notice subsequent to adoption 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 proposal 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, liquids with dilutions, liquids without 

dilutions). 

Although the 0.5% VOC limit poses significant challenges, CSPA member companies are not 

opposing the new VOC limit and commit 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 industrial users. The ARB’s proposed 3% VOC limit 

poses a substantial challenge for product manufacturers. This revised 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 removing difficult soils and heavy soil buildup without 

streaking or haze. 

Product manufacturers will face a particularly 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 residue 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 reduction in the VOC content for this product 

category, CSPA member companies commit to expend the amount of money to conduct the 

extensive research, development and engineering efforts necessary to ensure that the 

reformulated product: (1) achieve efficient cleaning, (2) minimize streaking, and (3) minimize 

residual compounds that remain on the glass that attract grime that 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 Grill Cleaner product categories are reasonable and 

necessary. The proposed revisions to the VOC limits, effective date, and definitions for this 

product category are needed to assure that products 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 proposal to include spot remover products used 

on dry clean only fabrics into the currently regulated “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 trichloroethylene for the Spot Remover category to 

newly added products (effective Dec. 31, 2012). 

6. Silicone-based Multi-purpose Lubricants

CSPA member companies do not oppose ARB’s proposal to ban the use of perchloroethylene, 

methylene chloride and trichloroethylene 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 included 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 different types of products — including lithium 

greases, moly greases, Teflon-based, cutting oils, anti-seize, chain and cable, gear, gun oil, etc. 

All of these products have different uses for different consumers and different VOC 

requirements; they do not fit into a single “one size fits all” category with one regulatory limit. 

 In addition, the 2012 effective date proposed does not provide adequate 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 consistent 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-defined 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. “Anti-Seize Lubricant” may include food grade lubricants. 

“Anti-Seize Lubricant” does not include “Cutting and Tapping Oil,” “Gear, Chain and 

Wire Lubricant,” “Multi-purpose Lubricant,” “Multi-purpose Dry Lubricant,” 

“Penetrant,” or “Silicone-based Multi-Purpose Lubricant.” 

 “Cutting and Tapping Oil” means any lubricant specifically designed or labeled for use 

in metalworking operations that include drilling, cutting and tapping metals. “Cutting 

and Tapping Oil” may include food grade lubricants. “Cutting and Tapping Oil” does not 

include “Anti-Seize Lubricant,” “Gear, Chain and Wire Lubricant,” “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 Tapping Oil,” “Multi-purpose Lubricant,” “Multi-purpose Dry 

Lubricant,” “Penetrant,” or “Silicone-based Multi-Purpose Lubricant.” 

“Gun Oil/Lubricant” means a product designed and labeled exclusively for the 

lubrication of firearms and/or the protection 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 lubricants. “Rust Preventive or Rust Control 

Lubricant” does not include products used exclusively on firearms, mold release 

products, “Anti-Seize Lubricant,” “Multi-purpose Lubricant,” “Multi-purpose Dry 

Lubricant,” “Penetrant,” or “Silicone-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, while providing clearer definitions and less 

uncertainly regarding what products 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 Products), 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 that 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 Other 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 regulated categories. A few of 

the products are for Industrial Use 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 determine 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 notice subsequent to adoption 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 functioning aerosol version, 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 action of an appropriate amount of propellant 

that provides additional viscosity reduction and proper delivery characteristics. Addition of LVP 

solvents is not an option in this category. 

In order for the compound to function properly after delivery, the dispensed product must return 

to its original grease state as rapidly as possible. This requires the use of a fast evaporating 

thinning solvent. Although acetone is a fast evaporating VOC-exempt solvent, it cannot be used 

in large amounts because it is not miscible with the petroleum-based greases that are used, 

causing them to coagulate and come out of solution. Slower evaporating solvents prevent the 

recovery of the grease by maintaining the diluted 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 operations. 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 applications can lead to expensive 

down-time and equipment losses. Aerosol anti-seize 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 products 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 adoption 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 prohibition 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 only 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 label 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 matter, 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 needed 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 subsequent 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-day notice subsequent to adoption 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 that much of the VOC content of these products currently consists of 

sustainable bio-based citrus extracts. We suggest that ARB should encourage the use of renewable 

and sustainable bio-based materials in these products. Bio-based materials are made by 

photosynthesis from carbon dioxide sequestered from the atmosphere 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 have very positive profiles for health and safety of humans and 

the environment. We believe that encouraging biobased 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 that does not inhibit the use of renewable and sustainable biobased VOC materials or increase the use of materials that increase net carbon emissions. 

CSPA therefore is willing to accept the 1% limit proposed for “Heavy-Duty Hand Cleaner or 

Soap” if a 5% VOC limit is allowed for “Special-Purpose Heavy-duty Hand Cleaner” defined as 

those labeled exclusively for removal of a few specific hard-to-remove soils where water is not 

available for rinsing. We therefore ask the ARB to consider the following changes to the 

proposed rule 

ARB should add or modify the following 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 necessitating the use of water. “Special-Purpose 

Heavy-duty Hand Cleaner” does not include prescription drug products, “Antimicrobial 

Hand or Body Cleaner or Soap,” “Astringent/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 and soils such as oil, grease, grime, shellac, putty, printer’s 

ink, paint, graphite, or cement, from the hand 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/Toner," "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 Detergent" (including antimicrobial), "Medicated 

Astringent/Medicated Toner," 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 personnel working out of mobile units in the field 
CSPA 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 CSPA 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, which we believe are important goals for ARB as 

well as our industry. 

CSPA has surveyed major marketers of these products 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-Purpose Heavy-Duty Hand Cleaners” as defined above. 

A copy of the specific survey results can be provided to ARB to allow emission reductions to be 

calculated for these categories and limits. We therefore urge ARB to seek to have this issue 

addressed further in a 15-day notice subsequent to adoption 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. Adequate 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 significant reduction in the VOC content for this 

product category, CSPA member companies commit to expend the considerable amount of 

money to conduct the extensive research, development and engineering efforts necessary to 

ensure that the reformulated products are effective while maintaining the low active ingredient 

levels in current products. 

This product category is subject to regulation under the Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA)3

 and the California Food and Agricultural Code.4 Under both federal 

and state law, any new formulation 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 both the federal and state agencies imposes a 

significant additional – and time-consuming – requirement on product manufacturers. Therefore, 

the December 31, 2013, effective date for this product category is both reasonable 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 manufacturers. Notwithstanding these challenges, CSPA 

member companies commit to expend the considerable 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 engineering efforts necessary to ensure that the 

reformulated product remains effective and affordable 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 further complicates manufacturers’ 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 wasps 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 this product category constitutes a significant 

reduction of the currently applicable regulatory standard. CPSA 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 maintain 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/spray technology changes, and product testing, 

including the consumer testing and storage and stability testing required for these types of 

aerosol products. Thus, the proposed 2013 effective date for the revised VOC limit is both 

reasonable and necessary. 

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

This broadly defined category of products performs many separate and distinct functions on 

different metal substrates for a variety of household, institutional, and commercial 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 technological challenges for 

manufacturers. Despite these challenges, CSPA member companies commit to expend the time 

and monetary resources to conduct research, development and engineering efforts need to 

reformulate our products to meet ARB’s very stringent 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 trichloroethylene in this product category. 

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

1. CSPA Generally Supports the Proposed Revision to the Most Restrictive Limit 

Provision. 

ARB’s proposed revision to 17 CCR § 94512(a)(3) provides 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 statewide 
CSPA Comments on Board Agenda Item # 10-10-7 

November 16, 2010 

Page 12 of 19 

regulation). CSPA generally supports the “bright 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 unintentionally removed an important text of the 

existing regulation stating that this provision does not apply to certain Disinfectant/Sanitizer 

products. Thus, CSPA urges ARB to restore the following text from the existing regulation: 

Notwithstanding the foregoing above, this provision does not apply to 

“Disinfectant”/”Sanitizer” products labeled as “Bathroom and Tile Cleaners,” 

“Glass Cleaners,” “General Purpose Cleaners,” “Toilet/Urinal Care Products,” 

“Metal Polishes,” “Carpet Cleaners,” or “Fabric Refreshers” that may also make 

disinfecting/sanitizing or anti-microbial claims on the label. 

Unless this language is restored, the adoption 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 develop 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, presenting pertinent information in three tables 

eliminates duplicative language in the seven subsections contained in the current regulation. As 

a practical matter, this is the type of information that is more clearly presented 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 requirements of that section. We support this being 

corrected in a 15-day notice 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 reported in the 2006 Survey as grouped organics, adequate data do 

not exist to determine to what degree these surfactants are used in the categories of products. 

Although we do not believe that this prohibition is justified based on the environmental impacts 

of the low levels of use of APEs in these products, and know of no reason to believe that any 

additional APEs would be used in reformulating 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 Appropriate Revisions to Method 310

Two modifications are being proposed to ARB 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 content, there are many analytical 

methods that may be use for analyzing the aromatic 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 telephone conversation between ARB staff and 

representatives of a CSPA member company. Moreover, there 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 analytical chemist must select the 

method that is most appropriate for measuring 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 analytical methods is useful, but urges ARB to include 

a caveat or disclaimer that care must be taken 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 should be allowed to be 

used. This is particularly true for the ultraviolet absorption method that is commonly used in 

industry for detecting aromatic content. Attached please find a matrix assessing the capabilities 

and limitations of the various analytical 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 the 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 “third 

increment toward fulfilling the commitment for VOC reductions for consumer products” (page I4). It is further stated that, “Because California has unique air quality problems, reducing VOC 

emissions from all categories, including consumer products, to the maximum extend feasible, is 

necessary to attain the federal and state ambient 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 reductions are necessary to attain the national 

and State ozone standards, the reductions from 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 evaluated 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 intent 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 Safety Code, sections 40910 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 Act, which declares that the federal air quality 

standards are to be achieved “...as expeditiously as practicable...” (See sections 172(a)(2), 

181(a), and 188(c) of the federal Clean Air Act). 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 adequate to demonstrate that this regulation is 

“necessary to attain the federal and state ambient air quality standard for 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 categories 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 sources until modeling showed attainment of the 

standard at all locations in the modeled region. But different sources have very different impacts 

on ozone formation per mass emissions, due to varying 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 revision, 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 consumer 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 demonstrated that even under highly VOC-limited 

conditions where ozone formation is highly sensitive to overall VOC levels, ozone formation 

was not at all sensitive to consumer product VOC emissions. 

The attainment demonstration modeling for the 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 reason 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 contracted in 2007 with Sierra 

Research and Environ to conduct a remodeling study, co-funded by nine national consumer 

product industry associations, to determine the ozone sensitivity of consumer product VOC 

emissions in the South Coast in 2023, and determine what level of emission reductions might 

actually be necessary. The remodeling study was completed along with the final report from the 

study, “Assessment of the Need for Long-Term Reduction 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 reductions suggested in the South Coast AQMP 

would have no impact on ozone attainment anywhere 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 being 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 measures 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 similar 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 consumer 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 consumer products emissions. The reduction 

commitment for CTS-04 was not used to reduce any 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 source-sensitivity studies provide 

important information to support the 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 provides further reasons for the allocation 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 actually 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 ISOR not only misrepresents industry’s position, but 

also posits an extreme interpretation that has seldom 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 feasible 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 been developed or marketed can be deemed 

to be technologically or commercially feasible by ARB. 
CSPA Comments on Board Agenda Item # 10-10-7 

November 16, 2010 

Page 16 of 19 

In interpreting the term “commercial feasibility,” ARB uses the International Harvester case6 to 

argue that all consumer preferences do not have to be met as long as “basic market demand” is 

met. The example given relates to glass cleaners, 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 relates 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 tasks for which it is used. 

Moreover, CSPA believes that ARB has sought to assure the feasibility of its proposed limits and 

other provisions in a manner more consistent with 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, and not revert to an extreme and unreasonable interpretation that 

would result in limits that would not allow effective 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 materials that may result in higher 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 assessment that the 2006 Consumer and Commercial 

Products Survey and other related data collection 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 interpretation of that data in establishing technologically and commercially 

feasible standards. This may not be true, however, 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-speciated 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 Rulemakings But Questions Some Cost Estimates. 

The proposed regulation would require reformulation of 1,467 products (see page V-37) and 

estimates total industry costs of approximately $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 initial 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-to-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 existing 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 ingredients postulated for complying make even 

less sense. 

• Low-Estimate reformulation costs for reformulating insecticides of $1,641 for Flying 

Bug and $298 for Wasp or Hornet. These costs 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 ingredients for Flying Bug Insecticide that is 

based on reducing the level of surfactants 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 underestimated low-estimate of nonrecurring costs is 

incurred per company instead of per product in calculating total industry costs (see Table 

VIII-3). There is no possible economy of scale that would allow a company to reformulate 

their entire product line for a few hundred dollars. 

• The assumption that pesticide and disinfectant (FIFRA-registered) products barely 

exceed other household products in low-estimate of nonrecurring product development 

costs (Appendix E, Table E-1) and in the high-estimate cost are actually 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 recent survey of member 

companies relating to “reasonably prudent precautions” taken to avoid non-California products 

being distributed in the state, CSPA found that a growing percentage of products are now being 

formulated for sale outside of California, and products whose sales are primarily or solely in 

California could occur if provisions become too restrictive for effective products 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 decision, as noted in the Initial 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 and 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 these 2010 Amendments. CSPA looks forward to 

working with other interested stakeholders and ARB staff on this important 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, the applicable “minimum recommended dilution” requirements do 

not apply to recommendations for the “incidental use of concentrated product to deal with 

limited special application such as hard-to-remove soils or stains.” 17 CCR §§ 94509(b)(1). 

CSPA supports ARB’s decision, as noted in the Initial Statement of Reasons (page ES-16), to 

develop an enforcement advisory to provide needed clarity regarding this provision. CSPA also 

looks forward to working with other interested stakeholders and ARB staff on this important 

clarification. 

SUMMARY AND CONCLUSIONS

During this rulemaking process, CSPA worked closely and cooperatively with ARB staff, 

environmental groups, air districts and various other stakeholders as part of the Consumer 

Products Regulation Workgroup (CPRWG). As a result 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 related 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 allowed for compliance. Notwithstanding these 

significant challenges, CSPA members commit to initiate actions necessary to reformulate a 

broad range of products to meet these challenging 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 into a 15-day comment period so that we can 

continue work with ARB to assure that all provisions are commercially 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 stringent 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 Affairs 
CSPA 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 Measures Branch, Stationary Source Division 

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

 Judy Yee, Manager, Implementation Section, Stationary Source Division 

 David Mallory, P.E., Manager, Measures Development Section, Stationary Source Division 

 Nicholas Berger, Air Pollution Specialist, Air Quality Measures Branch 

 CSPA Air Quality Committee & Task Forces 

 Laurie Nelson, Randlett•Nelson•Madden Associates 
Ralph M. Kowalik, Ph. D., ExxonMobil Chemical Company, 4Aug10 

Assessment of Test Methods to Measure Aromatic Hydrocarbons in Multi-Purpose Solvents a

for Inclusion in ARB Method 310 

Test Method Summary Description Suitable for 

Purpose (Yes/No/Maybe)

Capabilities / Limitations 

ASTM D 5443 Multi-column GC method that 

provides paraffinic, naphthenic, and aromatic fractions of hydrocarbon mixtures including separation by carbon number for the lower carbon numbers 

Maybe Method covers typical VOC a

ranges up to 270 oC; non-hydg., oxygenated solvents) may hydrocarbon groups and give results 

ASTM D 3257 Single, polar column GC 

method that separates aromatic hydrocarbons from nonaromatic hydrocarbons within mineral spirits range 

Maybe LVP range aliphatic hydrocar

boiling points > 235 oC (n-C1with aromatics and give erronnon-hydrocarbons (e. g., oxysolvents) may co-elute with agive erroneous results 

ASTM D 3710 Gas chromatography distillation 

(GCD) method that separates gasoline components by boiling ranges 

No Method does not separate ar

non-aromatics 

ASTM D 3606 2-column GC method that 

collects components lighter than octane and then uses a polar column to separate and measure individual component concentrations, in particular, benzene and toluene 

No Method does not measure C

aromatics 

CSPA Comments on Board Agenda Item # 10-10-7 
Ralph M. Kowalik, Ph. D., ExxonMobil Chemical Company, 4Aug10 

ASTM D 5580 2-column GC method that splits 

off groups of aliphatic and aromatic species in finished gasoline via a polar column and back flush and then measures remaining components 

Maybe Many oxygenated solvents ar

aliphatic hydrocarbons and daliphatic hydrocarbons C12 ainterfere with C9 and higher a

EPA 8021 (replaces EPA 602/8020) 

General GC method used to measure concentrations of specific compounds 

No Does not identify all aromatic 

that could be present in multisolvents and paint thinners 

EPA 8015 General GC method used to 

measure concentrations of specific compounds or ranges of organics (gasoline range organics, diesel range organics) 

No Does not separate aromatics 

aromatics in organic ranges; identify all aromatic compounpresent in multi-purpose solvthinners 

EPA 8270 General GC/MS method to 

measure concentrations of specific semi-volatile organic compounds (SVOCs) 

No Does not identify all aromatic 

that could be present in multisolvents and paint thinners; "the method is not appropriate quantitation of multi-compone

RECOMMENDED METHOD 

AFNOR NF M07-073 

UV absorption method to measure aromatics in heating fuels and other mainly saturated hydrocarbons 

Yes Measures aromatics in the VO

range; aliphatic hydrocarbons oxygenated solvents do not inneed to break emulsion produanalyzing; may need to skip awater and/or oxygenated solvpresent; method written in Fre

©2010 ExxonMobil. Use of this information is limited to the specified recipient. While the information is accurate to the best of our knowledge and belief alimited to the information as specified. No representation or warranty, expressed or implied, is made regarding the information, or its completeness, merch

particular use. The user is solely responsible for all determinations regarding use, and we disclaim liability for any loss or damage that may occur from the 

ExxonMobil does not guarantee typical (or other) values. Test methods are available upon request. 

CSPA Comments on Board Agenda Item # 10-10-7