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PROPOSED AMENDMENTS TO THE
STATEWIDE REGULATION TO REDUCE
VOLATILE ORGANIC COMPOUND E SIONS
FROM CONSUMER PRODUCTS - PHASE II ..
STAFF REPORT
STATE OF CALIFORNIA
AIR RESOURCES BOARD
ST~~TIONARY SOURCE DIVISION
OCTOBER 1991
State of California
AIR RESOURCES BOARD
PROPOSED AMENDMENTS TO THE
STATEWIDE REGULATION TO REDUCE VOLATILE ORGANIC COMPOUND EMISSIONS
FROM CONSUMER PRODUCTS
- PHASE II …,
Prepared by:
Solvents Control Section
Criteria Pollutants Branch
. ‘Stationary Source Division
Reviewed by:
Peter Do Venturini, Chief,. $tationary Source Division
Ronald A. Friesen, Assistant Chief, Stationary Source Division
Dean C. Simeroth, Chief, Criteria Pollutants Branch
Peggy lo Vanicek, Manager, .Solvents Control Section
October 1991
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I state of California

AIR RESOURCES BOARD
staff Report: Initial statement of Reasons for Proposed Rulemaking
Public Hearing to Consider PROPOSED AMENDMENTS TO THE STATEWIDE REGULATION TO REDUCE VOLATILE ORGANIC COMPOUND EMISSIONS
FROM CONSUMER PRODUCTS -

PHASE II -
To be considered by the Air Resources Board on December l;ncoln Plaza
Auditorium
400 P street
Sacramento, CA
Air Resources Board
P.O. Box 2815
Sacramento, CA 95812
13, 1991 at
This report has been prepared by the staff of the California Air
Resources Board. Publication does not signify that the contents
reflect the views and policies of the Air Resources Board t nor does
mention of trade names or commercial products constitute endorsement or
recommendation for usee
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IABLE OF CONTENIS
CQntents
Io !otcodYttjOD and SUUJDarYo.Ge.~o~09QQ~ .. “o.~~o”nO~06~O&Q onoooG”o.”,,&ol
A” OverY i ew 0 .. <) ” G <) ” <) ” ” .. ‘” .. ” <) ” 0 ” <> …… 0 .. 0 0 .. $ 0 .. ” ., ” 0 ., ” ” ” 0 ” ” ., ” ” ” n ” 0 .. ‘” ” ” ” 1
B.. SurIIllary II ‘” ” ‘” .. $ 0 <) 0 ‘” 0 0 ” ” ” ” <II ” (l .. <) .. ” ” .. <) <) I) .. ” ” ” $ e ” ” ” ‘” 0 0 0 0 .. ” e ” …. ‘” ‘” ., ‘” ” 2
C” Reconwnendat ions” .. G .. <> ” .. ” .. 0 0 0 ~ 0 $ …. <’> .. ” 0 ” <> ‘” ” 0 ” ” ” <> 0 0 0 G G .. ‘” ” ” …. ” ‘” 0 <l .. 8
lIe Need for Emissjon ReductiQns~”0~~&~qOQOOo”o.~~o”~”o~”,o~o”Qe~..~”&”,,,,.o9
AQ Air Qua 1; ty .. (I .. • ” <> ., …. ” …….. ” Q Q <> <> <> Q Q ” <> <> .. <> .. ” Q …… ” ” .. .. €I .. .. .. .. .. €I (\ 0) ., <> .. .. ” .. .. ” ” .. .. ., {) .. ” (l .. ., ” .. <> .. ” 13
C.. California Clean Air Act Requirementso ,,”" ~oaoo .. o~ .,0,,14
III~ ?rQdu~t Descri~iQns and Summary of the Proposed Amen~ .. ” “’0 .. 15
A.. Commercially and Technologically Feasible VOC Standards ” 15
80 Description of the Categories Proposed for Amendment …. oooo o19
C., Proposed Standards and Standard Effective Oatesoooooo .. o .. .,o 27
D., Em; ss; on Reduct; on S I) …. 0 …… ” ……. <> .. ” <It .. O”000o~”’0eeeee32
FG Add; t i ana 1 Amendments …….. 0 …. ” …. 0 .. <) 0 ” ” .. ” ” <> .. 0 ” …. ” ” <> <> .. ” .. 0 .. ” <> ” .. ” e ” ,,33
IV ” Impacts Assessment <) 0 0 <>”"” .. ” .. 0 .. 0″ 0 …. ” ~,,”’39
B0 Economi c Impacts Q ” ” ” .. ” ” .. 0 .. ” ” eo” ” .. ” & ” …. ” ” 0 0 ” ” ” 0 ” ” .. ~ ” ” .. 39
C” Sma 11 Bus i ness Impact s ” 0 ” .. ” …. 0 0 0 ” ” ” .. ” .. ” ” ” ” ” .. 0 ” ” Q .. ” ” …. 0 .. ” ‘” 41
\j P~I – Follow Up Issues” .. o.. ” …… “”" .. “o .. oo .. “”o”" .. .,o …. ” .. ” .. ” .. ” .. “~,,,,o42
A” Sell-Through Period for Non-Complying Productso”,oooo”"oooo”"oeo42
BoG1as s Cleaner s …. ‘” …. 0 ‘” €I …… 0 ” ” 0 .. <{) ., ., ” ‘” 0 ” 0 ” ” ” ” ” .. ” ” ” ‘” ., 0 .. ., ” ” ,,45
C.. Bathroom and Til eel eaners .. ” ” ” ” .. 0 .. ., ” ” ” ” ” ” ” .. D .. ” .. ” ” ” ” .. ” ” .. ,,46
D” Laundry Pre-Wash Products … “”.”"e “”oo .. “‘ .. “”"”oooo” …. ” …. ” …….. “,,46
En Charcoal Lighter Material .. “”o”"o” “”" .. “‘ .. o”‘”o”o”"‘” .. “”" .. ,,,,0 .. ,,47
VI.. ~1] Issues” .. (> 0 .. ‘” {> e 0 0 ” ‘” 0 .. ” ………. 0 …. ” .. ” (> .. ” .. 0 .. ” <> 0″ .. ” ” 0 0 ., ” ” ” ” ” ” …. ” …. 49
A” Environmental Paths of vac Emissions to the Atmosphereo”"”"”",,,,,49
8″ Consumer Product Efficacy .. “” .. <>” .. “” …… “” .”"0.”"0 0″ ° “”"”" .. ” …… ” .. 51
C” T() x ; c A; reont am inant s .. 0 .. ” ” ” .. ” .. .. 0 .. ” .. .. ” ” .. ” .. ” ” ” .. ” ” 0 <> .. ” ” ” ” 0 ” <{) ‘” “…. 52
VI I” .P~;t.Category I ssues~~” ., …. ” …. ” ” ” .. ” ” ” ……… 0″ .. ” ” .. ” .. ” ” 0 0 .. ” ” …. ” ” ” • ” ” ,,54
Ao
Bo
Co
Appendix
1~ 1,1·.. Tr ; ch 1oroethane 0 0 e” .. ” ” …. ~ ‘” .. ” ” .. 0 …. <> .. G ” ” ” ‘” ” ” ‘-’ 0 0 ” ” 0 ‘” .. 0 ” … 0 <{) ,,54
Aerosol Disinfectants .. 0000″ 0″ e n” e” .. ” <>” … “”"”" 0″ 0″ <>” ” .. “”.”" ,,57
Personal Fragrance Products .. ” 0″ ” …… 00 0 00 0000″ .. 00″ “”"” …. “”,,62
1
3
4A
48
LIST OF TABLES
Number of Days in Which the state Ambient
Air Quality Standards Were Exceeded in
Selected A’;r Basins During 19890.,000000000000000000002
Ambient Air Quality Standards for Ozone
and PM IO .. ” ” ” 0 0 .. 0 .. ” 0 ” ” 0 ., .. ” ” 0 <l ” .. <> 0 10
VOC Emissions by Product Category (1990) .. 00000 .. 000 …. 0014
Summary of Products Which Comply with the
Proposed Standards (1/1/95) Q .. 0 0 .. ” ………. ” n no ………. ” …….. 18
Summary of Products Which Comply with the
Propos ed Stand ard s (1/1/97) ~ .. 0 0 …. 0 G 0 6 g ” 0 Q ” .. ” …. ~ ” .. ” .. 019
Table of Standards (Phase II)”ooo”oOOOOOOQoooooo”"o 29
6
7
8
9
10
11
12
Summary of Proposed Standards and Emission
Reduct i on s .. ” 0 0 .. 0 .. 0 eo …. ” ” .. ” ” 0 0 …. ” ” 0 .. 0 ” ” ” ” ” 0 .. ” …… ” 0 0 .. ” 30
voe Emissions Reductions from All Consumer
Products Regulations.o~0ee.eo”e.ao0G@oo000″00000000031
Definitions Proposed for Addition.”oeeoooooooooooo.eoo34
Definitions Proposed for Modification .. “”"”"”" <>”" .. “” .. 0 034
Definitions Proposed for Deletion”"”"”ooo 0000 00000 0000
Comparison of Cost Effectiveness of the Proposed
Amendments to the Consumer Products Regulation with
Cost Effectiveness of the Control Measures for
Cr; ter i a Po 11 ut ant s .. 0 …. ” …… ” .. 0 .. 0 0 0 .. ” ” ” 0 ” 0 .. ” ” 0 ” 0 ” ” II ” 0 41
Toxic Air Contaminants Identified by ARBo “00″”0000000053
1
2
3
4
5
LIST Of FIGURES
Area Designation for state Ambient
Air Quality Standard – Ozoneoo … 0 •••• 0 a 00 •• 0.000.11
Area Designation for state Ambient
Air Quality Standard – PM10 0 0 ••• 000.0.12
Typical Sell Through Period for Stores Having Sales
less Than $3,500,000 – Air Resources Board Retail
Store Survey 0 ‘” ” …… ” .. (I ” …. ” ” 0 …. ” ” ” …. ” …. ., 0 ” ‘; 0 0 ” ” ….. ” .. 44
Typical Sell-Through Period for Stores Having
Sales Less Than $500,000 – Air Resources
Board Retail store Surveyo 00 ••••••••• 0.. 0.45
Vapor Pressures of HFC-152a/Ethanol/Water
Solutions at 70 °F ooo •••• o •••• o.o.”0.o •••••• 61
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IHTRODUCTION AND SUMMARY
.A.~ OVERVIEW
This report presents the staffts recommendations for a second phase of
standards to reduce Volatile Organic Compound (VOC) emissions from consumer
products sold in Californiae Standards are proposed for 12 new categories
of consumer products and several amendments are proposed to the existing
regulations for consumer products. These proposed standards and amendments
are designed to meet the requirements of the California Clean Air Act (the
UAct,HStatso 1988 9 Chapter 1568).
Two regulations have been adopted by the Air Resources Board (ARB or
the ItBoardll) to fulfill the requirements of the California Clean Air Act as
it pertains to consumer products. On November 8, 1989, the Board approved a
regulation to reduce volatile organic compound (VQC) emissions from
antiperspirants and deodorants. On October 11, 1990, the Board approved a
second, more comprehensive, regulation (Phase I) to reduce voe emissions
from 16 consumer products.
These two adopted regulations address 17 of the numerous categories of
consumer products SUbject to the Act. To achieve the maximum feasible
reduction in VOCs from consumer products as required by law 9 it is necessary
to examine the potential for emission reductions from additional consumer
product categorieso In the year subsequent to the Board action in
October 1990, ARB staff conducted a survey of consumer products and
conducted technical investigations to determine if there were additional
product categories that could contribute to emission reductionSa Based on
the findings, staff are proposing to amend the statewide comprehensive
regulation to add standards for 12 new categories (Phase II)Q Additionally,
staff are proposing several amendments to the existing regulation to clarify
and improve the regulation.
-1 …
Bo> SUMMARY
L Why loes :the ARB need tQ regu Jate YOC em; ss j QOs frgrn cJillsymer t2r:odUkt~_.
further?
a~ Ambient Air Quality: California continues to have severe air
quality problems and emissions from consumer products contribute t~ t~ese”
problems. The state ambient air quality standards f~r Olone and partlculate
matter less than 10 microns equivalent aerodynamlc dlameter (PM10) dre
widely exceeded throughout Californiae Table 1 shows the number of days in
1989 that the state standards for ozone and PMIO were exceeded in
Ca1ifornia l s major air basinsc
Table 1
Number of Days in Which the state Ambient Air Quality standards
Were Exceeded in Selected Air Basins During 1989
Number of Days Standard Exceeded
Air Basjn
South Coast
San Francisco
San Di E!gO
Sacramento Valley
San Joaquin Valley
Ozone
211
22
158
61
148
~J~..-..Jlij~~~
:306
95
136
144
274
Source:: 1989 ARB California Air Qua’lity Data Surrmary, Vol~ XXI~
be Emissions: Consumer products are a significant source of vac
emissions in CaliforniaQ Consumer products are widely distributed goods
that contain varying quantities of VQCs. While the emissions from anyone
product may appear small, when combined in the aggregate, the emissions
contribute significantly to California l s air quality problems6 Based on the
1987 emission inventory, consumer products account for approximately
10 percent of the total non-vehicular vae emissions in the state, or about
200 tons per dayo
Ce California Clean Air Act: In 1988, the Legislature enacted the
California Clean Air Act to address the air pollution problems of
Californiao In the Act, the Legislature declared that attainment of the
California State health-based air quality standards is necessary to protect
public health, particularly of children, older people, and those with
respiratory diseasese The Legislature also directed that these standards be
attained by the earliest practicable datee
The Act added section 41712 to the California Health and Safety Code,
which requires the Board to adopt regulations to achieve the maximum
feasible reduction in reactive organic compounds (ROG or vac – for purposes
-2-
of this regulation. ROG s VQe) emitted by.consumer products. if ~he Bo~rd .
determines that adequate data exists for 1t to adopt the ~egulat,ons. and 1f
the regulations are technologically and commercially feas1ble and necessary.
In enacting section 41712. the legislature clearly gave the Board new
authority to control emissions from consumer products, a ca~egory of sources
that had not previously been subject to air quality regulatl0ns~
As defined in section 41712, consumer products are any chemically
formulated product used by household and institutional consumers including
but not limited to, detergents; cleaning compounds; po’lishes; floor
finishes; cosmetics; personal care products; home~ lawn, and garden
products; disinfectants; sanitizers; and automotive specialty productso The
definition of consumer products specifically does not include paint,
furniture coatings, or architectural coatingse
2~ What is being prQpo~ed1
The Phase I consumer products regulation currently sets forth voe
standards and effective dates for 16 categories of consumer productse The
staff is now proposing to add new regulatory standards and effective dates
for an additional 12 categories of consumer products. These categories
(identified as Phase II) are:
Aerosol Cooking Sprays
Automotive Brake Cleaners
Carburetor-Choke Cleaners
Charcoal Lighter Material
Disinfectants (Aerosol)
Dusting Aids
Fabric Protectants
Hand Dishwashing Detergents
Household Adhesives
Insecticides
Laundry Starch Products
Personal Fragrance Products
Certain of these categories are further divided into sUbcategories for which
separate VOC content limits are proposed&
In addition to proposing standards for 12 new categories of consumer
products, the staff proposes a number of ather modifications& These
modifications include: (1) changes and additions to the definitions set
forth in the regulation, (2) changes in some of the exemptions that are
provided, (3) clarifications to the language of the innovative products
provision, (4) changes to the specified test methods, (5) inclusion of
more explicit registration requirements, and (6) various other changes to
the existing regulatory languagee The modifications are a’lso proposed to
the test methods and innovative products provisions of the antiperspirant
and deodorant regulation, in order to provide consistency with the proposed
changes to the consumer products regulatione A copy of the proposed
amendments is included in the appendix0
The staff is continuing to have discussions with manufacturers of
consumer products sUbject to this staff proposalo To the extent these
discussions result in the need to modify the proposal, the staff will
present such changes at the hearingQ Specifically, representatives of the
personal fragrance industry have presented staff with an alternative
proposal to what is being proposed by staffe Unfortunate’Jy, the proposal
-3-
was presented to the staff as this report was being finaliz~d: “l”he staf’f
intends to evaluate the industry proposal and may have spec~flc ,
modifications at the hearing to the proposal contained hereln for personal
fragrance products~
3., What are the emissign reductions from the staff prQ~11
Total estimated emissions from the 12 product categories being proposed
for inclusion in the consumer products regulation are estimated to be 57,000
pounds per day (lbs/day)o If the Phase II amendments.are ~dopted, the
emission reductions that would be achieved are approxlmately 19,300 lbs/day
by January 1, 19990 This reduction represents about a 30 percent reduction
of the emissions from the products being proposed for controlo When these
potential reductions are added to the reductions to be achieved as a result
of the Phase I consumer product regulation and the deodorant and antiperspirant
regulation, the total reductions of vae emissions from consumer
products are approximately 118,300 lbs/day (about 60 tons per day), or about
a 30 percent overall reductiono il” l!jre the crgposed standards techno’logjcally and cQllIDerciiil]y feasible1
The standards proposed are technologically and commercially feasibleo
Currently there are products available in each product category proposed for
contro’i which comply with the proposed standards. Thus, the basic market
demand for these products will be ensured and the impact on the consumer
products mar’ket and the product choices available to the consumer will be
minimized. To achieve further emission reductions, additional future
effective standards are being proposed for some consumer product categorieso
For those products that have future effective standards, staff will work
closely with industry to monitor the progress in developing the new products
to meet the lower vac limitso -
Got ‘tlhat are the economic impacts of the proposed regulatirml
The cost effectiveness ratios for the proposed regulation range from
less than $0001 to $1004 per pound of VOC reduced. The lower cost
effectiveness ratio was calculated assuming that manufacturers would
reformulate a product to a similar product with no equipment change avero
The higher cost effectiveness ratio assumes that a product is reformulated
and requires change in production equipment. The assumption was also made
that manufacturers would market the reformulated product nationally~ This
range reflects the staffls best estimate based on the data available to
allow evaluation of the cost to all manufacturers and the uncertainty in the
cost to reformulate from the wide variety of products covered under the
regulationo Due to the complexity of the market it is not possible to
conduct individual analysis for each consumer producto
. The total annual cost to the entire consumer product industry is
estlmated to range from approximately 13 to 205 million do’llarso The
estimated averag~ annual costs associated with reformu’lating a single
product forrnulatl0n to meet the proposed regulation range from $15 600 to
$270,000 per producto ~,
-4-
00 What are the environmental impacts of the prQgoseg_staDd~
The proposed amendments limit the amount of VOCs in consumer products.
The primary environmental impact will be a decrease 1n voe emlSS10ns to the
environment from consumer productso Since VOCs are lnvo~ve~ In ~he ,
formation of tropospheric ozone, any reduction in voe ~m’~Sl?nS 15 expected
to result in a positive impact on air quality and publlC health~
No adverse environmental impacts from the implementation of the
proposed regulation have been identified.. The staff took into consi~eration
the impacts of the proposed amendments on stratospheric ozone dep~etlon,
global warming, water pollution, toxic air contaminants and landf111
‘loading ..
7Q What are staffpropQsals on the October 1990 Bgard OjL~ttjves?
During the October 1990 Board Hearing, at which the Board approved the
consumer product regulation (Phase I), several issues were raised by
industry representatives regarding the regulation& The Board directed staff
o address specific issues and report back to the Board in 19910 The Board
directed the Executive Officer, in ARB Resolution 90-60 (dated October 11,
1990), to: (1) gather additional data on the feasibility of a five percent
VOC standard for laundry prewash (all other forms) and bathroom and tile
cleaners; (2) stUdy the issue of whether a longer sell through period is
necessary for small volume retailers of consumer products; and (3) survey
the amount of vae emissions from charcoal lighter fluid in the state and
report on the appropriateness of contralo
Over the past year, staff has met with industry representatives to
discuss the issues raised at the Board hearing and has conducted the
consumer product voe survey which included requests for data on laundry
prewash, aerosol bathroom and tile cleaners and charcoal lighter fluido
Based on staff’s analysis of the data, staff recommend that the standard for
aerosol bathroom and tile cleaners be raised from 5 percent to 7 percent,
and that no change be made to the laundry prewash standard6 Charcoal
1ighter flu’id emissions were determined to be approximately 5,600 lbs/day
tatewide in California on a yearly basis or about 11,200 lbs/day if based
on peak summer season emissions& Based on this data, the staff is proposing
control of these emissionsG.
8.. How does staff provide assurance that there wjl] ~lLe a health.
problem from compliance with the standard for aerQsQ1=~infectaDts?
The staff has determined that the 60 percent standard oroposed for
aerosol dis’infectants is tecnnologically and conrnercially feasible and that
at a VOC content of 60 percent manufacturers can provide intermediate level
(i080, hospital level disinfectants that are tuberculocidal, fungicidal, and
can kill most viruses) aerosol disinfectants .. In response to concerns
raised by manufacturers, the Staff intends to recommend to the Board that
the ARB follow a policy which will guarantee that fully effective aerosol
disinfectants remain available to the publice If subsequent information
shows that these disinfectants can not simultaneously meet the proposed
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standard and kill or deactivate a group of target organisms~ the ~tandard
‘Mill be modified accord;ngly~ In determining what possible impacts the
standard may have on the health benefits of these ~roducts, both ARB and.DHS
staff will E~valuate the effectiveness of products formulated to comply wl~h
the standard and achieve intermediate-level, hospital disinfection accordlng
to the products l ability to kill or inactivate _S.taphYJQCQC~~ aureus” .
)almQneLL~ ~hQleraesuis, PseuQonomas aeruginosa, ~~_Ll~ tUbercuIQ~~
y~ ~j TCycQphytoo mentagrophytes, and any target organlsm or organlsms
which the EPA determines by notice in the Federal Register as a general- ..
purpose virucidal indicator(s) for showing activity against most hydrophl11C
and/or lipophilic v;ruseso ARB and DHS staff will jointly report to the
Board on the progress of manufacturers in developing complying products
which meet this criteriao If it is determined that the VOC limit proposed
by staff will not allow formulation of aerosol disinfectants which can
achieve intermediate level hospital disinfection, then the staff will make
appropriate recommendations to the Board to modify the standard to ensure
that the public will continue to have aerosol disinfectants that can kill or
inactivate the target organismso
:30 liIDLiliJJ these amendments affect the goals Qut]jM.!i.~:Ln=~the CQnSumer,
J:!J2.d..u..ttControl plan?
The Consumer Product Control Plan presented to the Board in ,July 1989,
established a goal of a 50 percent reduction of vac emissions by the year
2000~ The staff estimates that the antiperspirant and deodorants regulation
will result in a vae reduction of 8,000 lbs/day, and the Phase I statewide
comprehensive regulation 90,000 lbs/dayo The standards proposed in Phase II
will result in an estimated additional voe reduction of 19,300 lb/day,
bringing the total close to 118,300 lbs/day or approximately a 30 percent
reduction in vac emissions from consumer productse The staff intends, as
discussed below, to evaluate further additional opportunities for emission
reductions from consumer products.
lO~ What js planned for the future?
The staff plans to investigate the potential for further emission
eductions from consumer productso Several categories of emission sources
were not addressed at this time due to lack of resources or informationo If
the staff determines that it is commercially and technologically feasible to
reduce emission from these categories, staff will propose additional
standards at a later dateo One of the objectives for this yearts amendments to the regulation was to include an alternative compliance plan (ACP) system for manufacturerSn ~he purpose in pursuing an ACP is to use market incentives to provide
further flE!xibility to the industry in complying with this ruleo However,
due to resource limitations, the ACP was not fully developed in time for
consideration by the Board this yearo The staff are continuing to develop
proposed rE~gulatory language for an ACP program and are committed to
c~ntinue working with consumer products manufacturers to develop an ACP that
wl11 provide fleXibility to manufacturers, be enforceable, and be equitable~
-6 ….
The ACP presently under development and the Innovativ~ Products
rovision adopted by the Board last year, are two”alternatlve means to add
lexibility to a traditional IIcommand and control r:g~lat:ono Due to the
complexity of the consumer products market and the l1rnltatl0ns ~n ~ur
resources, it is becoming clear that other methods to reduce emlSS,?nS must
be explored. In 1992, as the staff con~inues to d:V~lop.the A~P, other.
~equlatory approaches such as the use OT economlC Incentl~es? labellng and.
educational programs will also be evaluated to determine If these have mer,t
for use to maximize emission reductions from consumer productso
The Act requires the Board to adopt regulations for consumer products
only if adequate data existse Several steps have been taken to obtain the
necessary information on which to base the proposed amendmentsQ A survey of
consumer products was conducted this spring to collect product formulation
and production data on 49 different consumer product categoriese The
information obtained was then used to prioritize the product categories for
~ontrol. Information requested in the survey included the following data
for each brand name marketed in California: (1) the product form and
function, (2) the annual California sales, (3) the product composition, and
(4) for aerosol products, the propellant content and compositiono A
detailed summary of the results of the survey can be found ‘in the Technical
Support Document (TSD)& Using the results from the survey, ARB staff
estimated vac emissions from each product category and identified products
with law vac emissionse In setting priorities, staff considered the
magnitude of emissions, information available in the literature, and the
potential for emission reductions. The initial staff proposal contained 30
new product categorieso Based on discussions with consumer product
manufacturers at 3 public workshops and numerous individual meetings, staff
modified the original proposal and have postponed consideration of 18
product categories pending further studyo.
In addition, a survey was conducted of over 7,000 health care
facilities in California, including hospitals, nursing homes, day care
facilities. veterinary hospitals and dental offices. This survey was
onducted to determine the disinfectant needs of the health care 4 communitYe
Staff have also coordinated the development of the amendments with the
Department of Health Services and the Department of Pesticide Regulationo
At the Boardls request. staff also conducted an investigation to
determine the impact on small retailers in California of the’l year sell
through provision, approved by the Board last year. To determine the
effect, staff conducted a survey of over 4,000 retail businesses in
California.
. The info~mation collected by staff from the surveys, workshops, and
lndustry meE~tlngs provided adequate data on which to base this staff
proposal. Th~s repor~ is accompanied by a TSD also prepared by ARB staffo
fhe TSD contalns detal1ed discussions of the information presented hereo
-7-
Co RECOMMENDATIONS
staff recommends that the Board amend as appropriate the following
sections of Title 17 of the California Code of Regulations:
Section 94507 – Applicability
Section 94508 – Definitions
Section 94509 – Standards
Section 94510 – Exemptions
Section 94511 – Innovative Products
Section 94513 – Registration
Section 94515 – Test Methods
In order to achieve consistancy with these proposed amendments, the
staff also recommends that the Board amend sections 94503~5 (Innovative
Products) and 94506 (Test Methods) of the antiperspirant and deodorant
regulation~
The proposed amendments are technologically and commercia’lly feasible
and necessary to carry out the Boardls responsibilities under Division 25 of
the Health and Safety Codeo Staff will periodically report back to the
Board on the implementation status of the regulationo Staff intend to
closely monitor industry efforts at meeting the technology-forcing limits,
and will also report to the Board on industryls progresso.
-8-
II.
KEED fOR EMISSION REDUCTIONS
AQ AIR QUALITY
In order to protect Californials popu’lation from the harmful effects
of ozone and PM-lO (particulate matter less than 10 microns equivalent
aerodynamic diameter), federal and state air quality standards for these
contaminants have been establishedo These standards are shown in Table 26
The state hourly ozone standard is 0609 parts per million (ppm) and the
national hourly ozone standard is 0012 ppmc The state PM~lO standard for a
24 hour period is 50 micrograms per cubic meter (ug/m3) and the nationa<1
standard ;s 150 ug/m3, determined over a 24-hour periode
Ozone formation in the atmosphere results from a series of chemical
reactions between volatile organic compounds (VOCs or ROGs) and nitrogen
oxides (NOx) in the presence of sunlight. PM-lO levels are the result of
both direct and indirect emissionse Direct sources include emissions from
fuel combustion and wind erosion of soil. Indirect PMIO ambient levels
result either from the chemical reaction of VOCs, nitrogen oxides. sulfur
oxides and other chemicals in the atmosphe~e or the condensation of such
]ases that are emittedo.
Today, over 90 percent of California’s population live in areas that
are non-attainment for both the state ozone and PM-IO standardo Figure 1 is
a map showing the attainment status of California’s air basins and counties
with regard to the ambient air quality standards for ozone& The lined and
cross-hatched areas represent the 32 counties that are designated nonattainment
for the state ozone standard. Figure 2 is a map showing the
attainment status for California air basins and counties with regard to the
state ambient air quality standard for PM-IDo As shown in the map, 13 air
basins or portions thereof, covering 50 counties have been designated non
attainment for PM-IOo.
~9-
TABLE 2
Ambient Air Quality Standards for Ozone and PM~lO
Pollutant
Ozone
PM-IO
Averaging
lime
1 hour
Annual Geometric
Mean
24 hour
Annual Arithmetic
Mean
state
Standard
0&09 ppm
(180 ug/m3 )
30 ug/m3
50 ug/m3
-10-
Nat ‘j ona 1
~=~
0012 ppm
(23:) ug/m3 )
150 ug/m3
50 ug/mJ
Figure 1
OZONE
UNCLASSIFIED
ATTAINMENT
BAlUN VALLE.YS
~.///
~
AREA DESIGNATION*
FOR STATE AMBIENT
AIR QUALITY STANDARD
~OIlTH
l~O.TH
• PURSUANT TO SECTION 39608 OF THE CAUFORNIA CLEAN AIR ACT.. TSD .. 4/91
-11-
Figure 2
i~REA DESIGNATION*
FOR STATE AMBIENT
AIR QUALIT STANDARD
SUSPENDED
PARTICULATE MATTER
(PMIO)
LEGEND
UNC!~SSIFlED
* PtJRSUANT TO SECTION 39608 OF THE CAUFORNIA CLEAN AIR ACT~
-12-
TSD .. 4/91
B0 EMISSIONS
Health and Safety Code section 41712 requires the Board to achieve the
maximum feasible reduction in reactive organic compounds emitted by consumer
products~ As defined in the regulation~ VOCs are reactive organic ,~
compoundsb VOCs are defined as any compound containing at ‘least one atom at
carbon, except methane, carbon dioxide, and certain other organic compounds
determined by the Environmental Protection Agency (EPA) and the ARB to be
non-photochemically reactiveo.
While all VOCs are potential contributors to air pollution, the staff
are also aware that some VOCs used in consumer products have very -low vapor
pressures, and due to the product formulation characteristics and product
use, do not contribute to as great an extent as the more volatile VOCSn
Based on staff’s evaluation of the consumer products being proposed for
control, the regulation provides that only those compounds that exert a
vapor pressure greater than On1 mm Hg when measured at 20 degrees Centigrade
will be counted toward the emission estimateso.
The emissions from all consumer products are estimated to be about 200
TID in 1987 (excluding aerosol paints) and account for approximately
10 percent of all the non~veh;cular voe emissions in Californiae This is a
significant source af voe emissions and if not regulated the percentage
contribution to the total smog-forming emissions will increase as
California’s population continues to grow and the emissions from automobiles
and factories are increasingly regulatedo
The estimated emissions of VOCs from the 12 consumer products being
proposed for regulation were over 57,000 lbs/day (2805 TID) statewide in
19900 The emissions from these products are summarized in Table 30 The
emissions from these products account for approximately 15 percent of the
to~al consumer product emissions. Insecticides are the largest category
belng proposed for control at 18,500 lbs/day followed by personal fragrance
products at 10,900 lbs/dayo These emissions estimates were calculated based
on the responses to the VOC consumer products survey conducted bv ARB staff
n the spring of 1991 to determine VOC emissions for these and other
productsb
-13-
Table 3
vac Emissions by Product category
(1990)
product Categor~
VOC Emissions
lbs/day
Aerosol Cooking Spray 1,500
Automotive Brake Cleaners 1,600
Carburetor Choke Cleaners 3,300
Charcoal Lighter Fluid 5,600
Disinfectants (Aerosol) 7,600
Ousting Aids 1,000
Fabric Protectants 440
Hand Dishwashing Detergents 800
Household Adhesives 2,400
Insecticides 18,500
Laundry Starch Products 3,400
Personal Fragrance Products _10,900
Total: 57,000 lbs/day
(28g5 TID)
Source: ARB 1991 Consumer Product Survey
c. CALIFORNIA CLEAN AIR ACT REQUIREMENTS
The California Clean Air Act (CCAA) of 1988 requires, in part, (Health
and Safety Code section 41712) that on or before January 1~ 1992, that the
ARB adopt regulations to achieve the maximum feasible reduction of reactive
organic compound emissions from consumer productse Section 41712 also
provides that the Board shall not adopt regulations unless the regulations
are technologically and commercially feasible and are necessary.
The California Clean Air Act further requires that each district that
is nonattainment for the state air quality standard for ozone, carbon
monoxide, sulfur dioxide, or nitrogen dioxide to develop a plan for
attaining and maintaining the standards by the earliest practicable date and
to achieve a reduction in districtwide emissions of 5 percent or more per
year for each nonattainment pollutant or its precursorso
As described in this staff report, consumer products are a significant
source of vac emissions in Californ;ae The VOCs used in consumer products
are photochemically reactive and contribute to the state ozone and PM-IO
problemo Because of the serious air quality problems in California and the
inability of most populated areas to meet the state and federal standards
for ozone and PM~10, it is necessary to regulate consumer products and
achieve emission reductions from this solvent source category to the maximum
extent feasibleo
-14-
II16
fRQDUCI DESCRIPTIONS AND SUMMARY OF THE PROPOSED AMENDMENT~
Aa COMMERCIALLY AND TECHNOLOGICALLY FEASIBLE VOC STANDARDS
Health and Safety Code Section 41712 requires that all consumer product
regulations adopted by the Board must be technologically and commercially
feasibleo Last year, during the development of Phase I consumer product
standards, staff established criteria that were used to develop VOC limits
that would meet these statutory standardso Staff has used the same criteria
during the development of the Phase II proposal ..
In general, staff tooK the view that within a given product category,
products that perform similar functions should not have large differences in
VOC content.. The underlying question is, IIIf other products have a low VOC
content, while performing similarly, why ;s this manufacturer not able to do
the same or better?1D For all of the product categories proposed for
regulation, there exist complying products currently on the marketo This
fact creates a strong presumption that the proposed standards are
technologically and conrnerc;ally feasibleo Further discussion of these
concepts ;s presented below~
1~ Commercjally Feasible
The term IIcommercially feasible” is not defined in the Health and
Safety Code .. In interpreting this term, the staff has utilized the
reasoning employed by the United states Court of Appeals for the District of
Columbia in interpreting the federal Clean Air Acto In the leading case of
International Har~ester Company y. Ruckelshaus, (DoCo Ciro 1973) 478 Fo2d
615, the Court held that the Environmental Protection Agency could
promulgate technology-forcing motor vehicle emission standards which might
result in fewer models and a more limited choice of engine types for
consumers, as long as the basic market demand for new passenger automobiles
could be generally meto
Following this reasoning, the staff has concluded that a regulation is
Ilcommercially feasible U as long as the ltbasic market demand u for a
particular consumer product can be meto While the proposed standards are
-15-
not expected to eliminate any product forms or types, the staff does not
believe that the Legislature intended that manufacturers be guaranteed the
right to sell consumer products in all the same variety o~ forms and types
that presently existG To adopt such a narrow interpretatlon would be
“inconsistent with the clearly expressed legislat’lve intent that Il.~~the
state board shall adopt regulations to achieve the maximum feasib’le
reduction in reactive organic compounds emitted by consumer” productso. 0 II
(Health and Safety Code section 41712(a))o
Some commenters have expressed the view that consumers do not have a
!lbasic market demand H for a general class of products, but that consumers
instead have a number of a separate and distinct IIbasic mar’ket demands!! far
many specialty products with differing characteristicse In the category of
“g l ass cleaners iR
, for example, some glass cleaners are armtonia-based and
some are vinegar-based$ Under the views of some commenters~ it might be
inappropriate for the ARB to establish a single standard for glass cleaners
(based on the IIbasic market demand ll for u a product that will clean glass U
),
because such a standard may not take into account the separate market demand
Jf some consumers for Jlanmonia-based glass cleaners il and the demand of other
consumers for Jlv;negar ….based class cleanersue Similarly, it has been argued
that separate “basic market demands ll must be recognized for all forms of a
product (i~eo, aerosols, pumps, solids, gels, etco), and that the ARB does
not have the authority to set a vac standard that would have the effect of
eliminating any of the existing product forms.
ARB staff does not agree with this view. ~very currently marketed
product or product form has some unique features that differentiate it from
other products. Consumers who purchase a particular product or product form
have demonstrated a preference over competing products that they d() not buy.
However, a preference for a particular product form is not the same as the
basic market demand for the function that the product performs. The
International Harvester case, ~, clearly makes this distinctione In
InternationaL Haryester, the court stated that the proposed emissions
standards would be feasible even though they might result in the
unavailability of certain kinds of vehicles and engine types which some
consumers preferred (e .. go, fast lImusclell cars), as long as the basic market
demand for passenger cars could be generally met. Applying this principle
to the area of consumer products, the proposed amendments allow the basic
market demand to be met for products in each consumer produ category, even
though for some categories it may no longer be possible to manufacture
certain product types or formulations. The ARB staff believes that this is
a common sense approach which is in full accord with the requirements of
section 41712 ..
Al~hough the ARB is not legally compelled to do so, for many product
categorles an attempt has in fact been made to accommodate differing
co~sumer preferences.. This;s reflected in those product categor;t~S for
WhlCh separate vac limits have been set for different product forms .. The
ARB will continue to use this approach in cases where it ;s both f~~asible
and appropriate to do so, in light of all the data and comments presented
during the regulatory processo
-16-
2~ Iechnologjcally Eeasible
The Health and Safety Code Section 41712(b) provides that the Board
hall not adopt consumer product regulations unless the regulations are also
“techno’log;ca”lly feasiblell~ Techno”logical feasibility “is a different
oncept than IIcommercially feasible ll
, and does not take into account the
cost of the product to be producedo Staff believes that a proposed standard
is technologically feasible if it meets at least one of the following
criteria: (1) the standard is already being met by at least one product
within the same category, or (2) the standard can reasonably be expected to
be met in the time frame provided through additional deve”iopment effortse
For all of the categories being proposed for contro’), both the initial
standards and the future effective standards, products are currently
marketed that comply with the regulation. Tables 4A and 48 below lists the
number of complying products for each Phase II product category~
-17-
Table 4A
Summary of Products Which Compiy with the
Proposed Standards (1/1/95)
Nu~r at
(:~~l.Yl.nq
PY”oouetJl I
:’otal ~
?roouct,l\
:1
?r.opo!lea.
stanciard.
‘~t % VOC
Proauet
Product Cateqory ~’orm
..
i (1/1/95) :;u.rvay .tl..V’@..\.1.ahle I: in ea
Ii
AeroBol Cooking Spray. All Forma I 18 ~ 5 31
i
Automotive Brake Cleaner. All Form. SO ·;0 45 i
I
CharcoA~ Lighter Mllter1.al A.l.l Form. f!1 I (L02 ;:3
- Ib/ata.n
Carburator Choke Cleaner. lUl ForJIUI I j , 75
I
69 24
i
:
Disinfectant. AerolJols I 60 -34 11
I
\
DU!ltinq Aid. Aerosols 35 ::8 tS
All others ~ :’9 12
Protectants All Form.. 7S 66
D1shwaeh.inq Dete.z:’qenta III Form. 2 157
- In Adhesives Aerollal 75 58 4S
1 All others \ 10 166
I
~
Insecticides …,
\ Crawlinq Buq All Form. I 40 10 134
Flfta and. Tick All Forma I 20 9 ~~ J
Flyinq Insect: 1\11 Form. I 0 .; ~ ~ 5
Foqgera All Form. I ~o “J 2 -: ]
i W…p ! ” Bornet: All ForIUI I 40 ! 37 22 Lawn I ,. Garden All FOr1J18 20 164 99
!
1\..1.1 Others All Form. 1 20 L29 1
j I i
For-. j
I
LAundry Starch Products ill. S 42
Personal Fragrance Products – I I Aftershave &I Body SpIaahell A~l Forma
I
60 198 58
co1oqn•• p Toilet Water PerfmuuJ ” All Fonll.ll I , 70 I 66′ 93
All. other A~l Forma I 50 I “~ 5 liS
!L ‘ ”’-~
*: UTQ Unable to quantify
Note: Kingsford has recently qualified a charcoal lighter fluid to meet
South Coast Air Quality Management District requirements and staff believe
that this product w;11 meet the proposed standards.
-18-
Table 48
Summary of Products Which Comply with the
Proposed Standards (1/1/91)
Proauct:. t: .LU~u.oa”", • I ~1\.U!lDer ot I
Product Category ~;’orm standard I ?rOductlJ I :::::e.plyl.uq
Wt % voc i.Xl Producc.SI
Survey i AV’a,1.1ahle
i
in
Carburetor: Choke Cleaners FOrl1Jl SO 69 lS
! OUatinq Aida Aero.ol 25 28
Fabric Protectant.
I
All Forms 60 I 66 59 l
I
I !
Household Adhes1veml Aerosol 5 a :;:2
\ !
Inaectl.cides ~
Crawling Bug (1/1/98) All Form. 20 ‘: 10 99
i
B@ DESCRIPTION OF THE CATEGORIES PROPOSED FOR AMENDMENT
lQ Aerosol Cooking Sprays
Aerosol cooking sprays are aerosol products designed either to
reduce sticking on cooking and baking surfaces or are applied on food,
or botho They are generally recognized as pan coating, pan release4
food release. no-stick, or flavored cooking sprays that are used in
professional and home settingso Professional settings may include
restaurants, cafeter;as~ and mobile kitchens~
Generally, aerosol cooking sprays help to reduce sticking in
foods and aid in the clean-up of food residues in COOKware, bakeware,
and utensils.. In some, cases, they are used as flavoring sprays ..
Healthwlse, the aerosol cooking sprays benefit people who are on low~
fat or restrictive diets because the cooking sprays contain little fat,
are low in calories, and have no cholesterol .. Since they are used as a
processing aid in the cooking and baking of foods or as flavoring on
foods. all listed ingredients must be “generally recognized as safe
(GRAS)U for use by the Food and Drug Administration~
The key ingredient is lecithin because it has excellent
emulsification properties. is a useful foam stabilizer’ and suspending
-19-
agent, has anti-spattering properties, and is a good release agento
Because of its reputation as a health food supplement~ lecithin is used
in fat-sparing formulations.
Based on the ARB vae survey, 45 aerosol cooking sprays were
reportedQ The estimated emissions for this category are 1,500 lbs/day.
20 Automotive Brake Cleaners
Automotive brake cleaners are products designed to remove oil,
grease, brake fluid, brake pad material or dirt from motor vehicle
brake mechanismse The solvents used in brake cleaners are used to
remove contaminants from brake components such as soils, brake fluid,
oils and greases and to ease disassembly or to provide final cleaning
during assembly. Most brake cleaner formulations are based on
chlorinated solvents that clean parts quickly without leaving a
residueo A typical brake cleaning formulation will primarily consist
of 1,1,1 Trichloroethane (methyl chloroform or TeA) and
tetrachloroethylene (perchloroethylene) blends, while non-chlorinated
brake cleaners may consist of toluene. acetone, xylene, terpenes,
petroleum distilates, methanol and ethanolo The recent amendments to
the federal Clean Air Act require the phase out of TCA~ Because of
this, it is expected that manufacturers will reformulate products
containing TCA, such as brake cleaners, to remove TCAo
Brake cleaning products are packaged in aerosol and liquid form~
Market shares for aerosol and liquid forms are 95 percent and 5 percent
respectively. Total emissions for this category are 1,600 lbs/day.
36 Carburetor – Choke Cleaners
Carburetor-choke cleaners are products designed to remove dirt
and other contaminants from a carburetor, but do not include products
designed to be introduced directly into the fuel lines or fuel storage
tank prior to introduction into the carburetor. Carburetor~choke
cleaners also remove dirt and other contaminants from such parts as
butterfly valves and choke linkages6
Carburetor-choke cleaners are sold in both the aerosol and liquid
forms. The aerosols are the most commonly used form because most
carburetors are cleaned while still attached to the engine. All
aerosols are sold with a th;n straw-like plastic tube which inserts
into the valve button orifice to allow for localized c’leaning of the
carburetor and its components. The liquids are usually used by
professionals and home mechanics who clean, repair, or rebuild engine
componentso The liquid products may be sold in 2 gallon, 5 gallon, or
larger sized containers (55 gallon drums). The li~uid containers are
usually not completely filled to allow head space for a dip basket.
Generally, liquid carburetor parts cleaners are also used to clean
other metal parts, whether the parts are engine components or note
-20-
Carburetor-choke cleaners contain VOCs that are solvents and
propellantso Typical aerosol formulations may inc!ud~ the following
ingredients in various combination – methylene chlorlde, .tol~ene,
xylene, acetone, alcohol, ethyl acetate, butyl acetate, dlacetone
alcohol, methyl ethyl ketone, 2 butoxyethanol, isopropyl alcohol,
l,l,l-trichloroethane, methanol, morpholine and cyclohexanol~
Propellants used include propane~ isobutane, a combination of both,
carbon dioxide, or dimethyl ether (DME)Q
Based on ARBis voe survey, 69 carburetor-choke c’leaners were
reportedo Of these, 53 are aerosols and 16 are liquidso The aerosols
account for a greater portion of the market and the majority of the
emissions. The emissions from this category are estimated to be
3,300 lbs/dayo
4a Charcoal Lighter Material
Charcoa 1 1; ghter mater; ali s def i ned ’1 n the proposed amendments
as any combustible material designed to be applied on, incorporated in,
added to, or used with charcoal to enhance ignitiono This does not
include electrical starters and probes; metallic cylinders using paper
tinder; natural gas; and propane. Charcoal lighter materials are
perhaps unique among the categories ‘included in the regulation in that
(1) a large portion of the product is converted to non vac combustion
by-products during usage, and (2) product usage tends to be very
seasonal (summertime) 6
Products typically used to light barbecue charcoals include
lighter fluids, paraffin cubes and wood chips, gels, IIfire rings U,
(metallic rings filled with fluid to light charcoal from underneath),
pre-soaked or “ready start U charcoal (essentially charcoal with lighter
fluid a1ready incorporated into it), and “bag-light!! charcoa’j (small
bags of charcoal which are lit with charcoal still in the bag)o Tests
conducted by the South Coast AQMD (SCAQMD) demonstrate that the
majority of VOC emissions from this category results from the use of
petroleum distillate-based charcoal lighter fluids (Haimov)6 These
petroleum distillate-based products are comprised of 100 percent VQe,
with physical and chemical properties similar to those of kerosene
(Lieu)o
Total sales of charcoal lighter material are estimated to be
between 26,000 lbs/day (1991 ARB vac Survey) and 30,000 lbs/day
(Nielsen) in Californiao Of this total, source testing conducted by
the SCAQMD and the Clorox Company show that approximately 20 percent of
the product used either evaporates or is otherwise not consumed during
combustion (Marinoff; Kennedy) 6 From this data, staff estimate that
the an~uaJ daily ~vergge VOC emissions from this category are
approx1mately 5,600 lbs/day of voe (based on assumed average sales of
28,000 lbs/day) in Californiao Since barbecuing may be more accurately
described as a seasonal activity (assuming majority of emissions occur
be~we:n May and October), staff also estimate summ~~_i]y avergge
emlSS10ns to be approximately 11,200 lbs/day vac (Perryman) 0 Because
«m21-
of the seasonal nature of barbecuing, staff expect that the summer
daily average emissions estimate is a more accurate rep~esentation of
the emissions which can impact ozone attainment strategleSn
In October 1990, the SCAQMD adopted a regulation for charcoal
lighter materials which limited maximum emissions from these products
to 0002 pound voe per start. This regulation formed the basis for
staffls proposed standard. To maintain consistency with this
regu’lation, staffls proposed standard and administrative requirements
for charcoal lighter materials are essentially identical to those
adopted by the SCAQMDe In this way, impacts to manufacturers and
consumers will be minimized while ensuring significant emission
r~eductions and continued product availability throughout California.
50 Disinfectants (Aerosols)
Disinfectants are defined as any product intended to destroy or
irreversibly inactivate infectious or other undesirable bacteria,
pathogenic fungi, or viruses on surfaces or inanimate objects~ Since
these products are intended to kill organisms, they are registered with
the Environmental Protection Agency as pesticides under the Federal
Insecticide, Fungicide and Rodenticide Act (FIFRA, 7 UaSoCo 136, et
seq.) and with the California Department of Pesticide Regulation
(formerly with California Department of Food and Agriculture) under the
newly~farmed California Environmental Protection Agencyo
Aerosol disinfectants are used by consumers to kill germs on
surfaces and to eliminate odors by killing household germs, mold, and
mildew in and around the homeo Typical areas of use include garbage
cans, hampers, bathrooms, and pet areas.
Disinfectants are available in aerosol ~ liquid, powder~ granule,
pump, foam, and towelette forms (1991 ARB VOC Survey) 0 Aerosol
disinfectants basically contain four components: (1) solvents, (2)
active ingredients, (3) propellants, and (4) other minor ingredientso
The solvents, which can also act as an active ingredient~ usually
include an alcohol (ethanol or isopropanol) and watero In addition to
alcohols, other active ingredients usually include a phenolic (eeg. 0phenylphenol)
or a quaternary ammonium compound (quats)o Propellants
are either a liquefied hydrocarbon (isobutane 9 n-butane, propane) or a
compressed gas (C0 2)0
Aerosol disinfectants dominate the household market, but their
sales volume ;s insignificant when compared to liquids and solid
disinfectants in the industrial/institutional (I&I) marketo While
aerosol disinfectants comprise less than 1 percent of the total
c~mbined h~usehold and I&I markets far disinfectants, they emit a
dlsproportlonately large 40 percent of the total VOC emissions from the
disinfectant category (1991 ARB voe Survey) 0 Staff estimates emissions
from aerosol disinfectants products to be approximately 7,600 lbs/dayo
-22-
6″ Dusting Aids
Dusting aids are products applied to dust cloths or dust mops to
increase their ability to attract and hold dust particleso Some
products are also used to clean surfaces such as wood paneling and
stainless steelo These products differ from products in the furniture
maintenance category in that they do not leave a wax or silicone based
coating and can be used to dust floors. Typically a hydrocarbon oil is
included in formulation as the primary dust attracting ingrediento
Dusting aids are composed primarily of light hydrocarbon oil and
solvent, water or both. The solvent is typically hydrocarbon although
some products contain methyl chloroform. Aerosols typically contain
hydrocarbon propellants such as isobutane and propaneo Other
ingredients that may be added in small amounts are emulsifiers,
cationic dust attractants, and fragranceo
Dusting aids are available in aerosol, pump spray, and liquid
forms, with the majority of the market and emissions from the aerosol
form. Emissions from the entire category are 1,000 lbs/day, with 97
percent of the emissions from the aerosol form~
7~ Fabric Protectants
Fabric protectants are defined to include produ s designed to be
applied to fabric substrates to protect the surface from,soil, dirt,
and other impuritiesu Excluded from the definition are waterproofing
products and products labeled and marketed for use only on fabrics
which are labeled for “dry clean on1 y ll”
Fabric protectants are available for a variety of products such
as clothing, outdoor equipment, furniture, and carpets” Fabric
protectants are typically sprayed onto the surface and allowed to dryn
The solvents in the product evaporate, leaving behind a resin film
which forms a barrier between the fabric and 50;10 Most of these
products use fluoropolymer resin dissolved in l,l,l·-Trichloroethane”
;\erosol products typically contain hydrocarbon or carbon dioxide as the
propellant.
Fabric protectants are available in aerosol, liquid, and pump
formso Of these, the aerosol sprays dominate the California market”
Emissions from this category are estimated to be 440 lbs/dayo
8ft Hand Dishwashing Detergents
Hand dishwashing detergent is a surfactant-based washing product
designed for hand dishwashing or other light cleaning taskso The
products are designed to be able to handle food soils, be mild on
hands, create high and long lasting suds, and rinse free of films and
spots” Almost all hand dishwashing detergents are liquids with the
exception of some powder products for the I & I marketo Liquid
-23-
products are aqueous blends of surfactants and powder products contain
surfactants, sanitizing agents and fil1erso
The survey results show that 14,000 lbs/day of vac from hand
dishwashing detergents are released into the envi~a~me~t~ However, not
all of the emissions will enter the atmosohereo Th1S 15 because hand
dishwashing detergents are often diluted in water solutions and are
disposed of down the draino Studies conducted by the Soap and
Detergent Association (SDA) show that up to 5 percent of the ethanol
content in hand dishwashing detergents can be released to the air
during use.. Other SDA studies that modeled the Udown the drain ll fate
of ethanol show that ethanol emissions from hand dishwashing detergents
disposed of into the wastewater system can be less than 1 percentn
In estimating emissions, staff assumed that 5 percent of the VOC
in hand dishwashing is emitted into the air~ Therefore, of the 14,000
pounds per day total vae emissions into the environment, 800 lbs/day
are emitted into the atmosphere$ Staff believe that this is a
conservative estimateo If actual vac emissions from the wastewater
system are higher than the results from the SDA studies, overall
emissions of hand dishwashing detergents may be highero Staff will be
working with staff from several regional water quality districts and
the South Coast Air Quality Management District, which has adopted a
rule requiring the quantification of vac emissions from wastewater
facilities, to confirm the relative emissions of 18down the drain ll VOC
from dishwashing detergentso
90 Household Adhesives
Household adhesives have been defined in the proposed amendments
to include products used to bond one surface to another by attachmento
Excluded from the proposed amendments are products used on humans and
animals, adhesive tape, contact paper, wallpaper, shelf liners, or any
other product where the adhesive has been incorporated onto or in an
inert substrateo In addition, products based on cyanoacrylate ester
monomers are proposed to be exempt from the proposed standardso
Household adhesives are used to repair and maintain a wide
variety of household items” These products are typically used to bind
materials such as glass, plastic, rubber, wood, and metal together.
Household adhesives are applied by brush, flow, wipe, and aerosol
spraYe These products contain various resins such epoxies, silicones,
and rubbers dissolved in both organic and inorganic solvento The
solvent ;s the media for transferring the adhesive materials to the
substrate and also acts to promote adhesion by wetting the surface$
Household adhesives are available in aerosol, gel, liquid and
other forms” Emissions from this category are estimated to be 2,400
lbs/da.y”
-24-
lac Insecticides
Insecticides are pesticide products intended for use against
pests such as insects and other arthropods found in or around the
household” All insecticides that are sold in California must be
registered with the U”S” EPA according to the Federal_Insecticide~
Fungicide and Rodenticide Act (FIFRA), and the state Department ot
Pesticide Regulation (OPR)”
Insecticides are divided into categories by primary uses or
unique product form” Primary use categories are crawling bug
insecticides, flying bug insecticides, flea and tick ‘insecticides, wasp
and hornet sprays, and lawn and garden insecticides” These primary use
categories contain a multitude of products forms that include aerosols,
pumps, liquids and solids& Insecticide fogger is a unique product form
category that includes products designed for one or more of the above
primary useso
Insecticides rely on pesticide active ingredients that are toxic
to the intended pesto These active ingredients’ toxicity can act to
poison and kill the pest or to regulate their growth~ Active
ingredients can work by contact or ingestion po;soningo Contact
poisons can either act quickly to IIknockdown u the pests, or act
residually to kill pests that will contact the poison after
applicationo New active ingredients such as late generation
pyrethroids can provide both knockdown and residual propertieso Active
ingredients in consumer product insecticides are generally in very low
concentrations of less than a few percent” The majority of the
formulation contents are the inert ingredients, which function to
propel, carry or deliver the active ingredient to the pestsQ
Aerosol products usually contain knockdown active ingredients to
allow the user to quickly kill insects sprayedo Aerosols in the
crawling bug, foggers? and flea and tick categories can also contain
residual active ingredients. The inert ingredients in aerosol
formulations include the propellant and the carrier systemso
Hydrocarbon prope’11ants are used in the large major; of the productso
Hydrocarbon solvents, water based emulsions, and 1,1,1 trichloroethane
(TeA) / hydrocarbon blends are used for carriers” In the category of
flying bug insecticide, water-based emulsions are the prevalent systemB
However, in crawling bug insecticides, the dominant carrier system is
hydrocarbon solventso TCA / hydrocarbon blends are widely used for
foggers and wasp and hornet insecticideso The aerosol products
contribute the largest fraction of VOC emissions in all insecticide
categories,.
The majority of liquid and pump products are water-based emulsion
products,. Liquids are usually sold in concentrated emulsions, which
require dilution prior to usee Pumps are usually sold in ready-to~use
concentrationso Solid products can be divided into dusts,
dissolvables, or baitso Dusts contain active ingredients mixed with
-25-
inert fillers or carrierso Baits contain active ingredients mixed in
inert materials such as food or attractantso
The survey results show that the vae emissions, fro~ in~ecticides
are 18,500 lbs/dayo In addition the category accounted for b,800
lbs/day of emissions in 1,1,1 Trichloroethanee
110 Laundry Starch Products
Laundry starch products are designed for application to fabric,
either during or after laundering, to impart and prolong a crisp, fresh
look and may also act to help ease ironing of the fabrico
Laundry starch products consist of starch, prope’llant (if
aerosol), surfactant (wetting agent) and silicone (ironing aid). The
principle function of starch in finishing textile fabrics is to impart
or accentuate the desired physical characteristics in the clothe In
laundry work in homes or in commercial laundries, and in finishing
clothing and other textiles, starch is used as a stiffening agent to
form a smooth surface which does not become soiled readily making
laundering easiero Starching washed clothes is a means of replacing
the original finish of the cloth which was partly or completely removed
by launderingo This finish, whether applied at the factory or in the
home or laundry, leaves the textile material smoother, brighter, more
pliable and holds down surface fibers; much starch, however, will
stiffen the textile goodse Finally, laundry starch products can also
extend the life of fabricse
Laundry starch products are packaged in aeroso1 9 pump, liquid and
solid (dry) formo The total emissions from this cateqory are
3,400 lbs/dayo
12~ Personal Fragrance Products
The personal fragrance category consists of a wide variety of
products designed primarily to add a scent to the human body or
clothing and includes perfumes, colognes~ toilet waters, body splashes
and aftershaveso Products in the personal fragrance category typically
contain fragrance oil in concentrations ranging from 1 percent to over
25 percent dissolved in ethanol and water. The concentration of
fragrance oil generally dictates the amount of product used per
application~ with perfumes applied by the drop and body splashes and
aftershaves splashed on by hand.
Personal fragrance products are available in many formso
Aftershaves and body splashes are generally liquid products, perfumes
and toilet waters are primarily in liquid and pump spray form, and
colognes are available in aerosol, pump spray, and liquid forms~
Emissions, almost exclusively ethanol, from the entire personal
fragrance category total 10,900 lbs!day with about 8,000 lbs/day
-26-
contributed from the perfume/cologne/toilet water category, about 29 800
lbs/day from aftershaves and body splashes, and about 80 lbs/day from
miscel~aneous personal fragrance productso
Co PROPOSED STANDARDS AND STANDARD EFFECTIVE DATES
The Phase II Consumer Products Regulation would establish VOC content
standards for 12 different consumer product categorieso The effective date
of the proposed standards for the Phase II product categories is January 1,
1995 1 with the exception of three categories. The effective date is one
year later for dis’infectants and insecticides, which are products that must
be registered according to FIFRA. To ensure consistancy with the South
Coast Air Quality Management District’s (SCAQMD) Rule 1174, the standard
effective date for charcoal lighter materials is January 1 9 1992 in the
SCAQMD and January 1, 1993 in all other areas of Californ;a~ In addition,
there are future effective standards for fabric protectants, crawling bug
insecticides, dusting aids, aerosol household adhesives, and carburetor
choke cleaners ..
The regulation prohibits the sale, supply, offer for sale, or
manufacture for sale in California of any consumer product which at the time
of sale contains volatile organic compounds in excess of the limits
specified.. Also, the standards are set on the basis of percent voe by
weight except for charcoal lighter materials which are set for pounds of vae
emissions per starte The percent by weight limits apply to products only
after the “minimum recorrmended dilution ll has taken placeo Spot or
incidental use of products with IIminimum reconmended dilution Jl in
concentrated forms ;s allowed so products such as general purpose cleaners
can be used occasionally in small amounts to treat hard-to·=remove soils.
Standards for hand dishwashing detergents apply only to the as-supplied
roducte This is because these products are all diluted far use, therefore
t is not required to account for differences between dilutable and readyo-
use products.. A summary of the proposed standards is shown in Table 50
-27-
Tab”le 5
Table of Standgr.Jis.
(Phase II)
Percent Volatile Organic Compounds by Weight
erQduct Cgtegor~
Aerosol Cooking Sprays
Automotive Brake Cleaners
Carburetor Choke
Cleaners
Charcoa’l Lighter
Materials *
Disinfectants
Aerosols
Dusting Aids
Aerosol
All Other Forms
bric Protectants
Hand Dishwashing Detergents
Household Adhesives
Aerosol
All Other Forms
Insecticides
Crawl ing Bug
Flea and Tick
F1,yi ng Bug
Foggers
Lawn and Garden
Wasp and Hornet
All Others
-28-
1/1/95
18
50
75
60
35
7
75
75
10
40
20
30
40
20
40
20
Future
Effective
i.Lkt~~
50
(1/1/97)
25
(1/1/97)
50
(1/1/97)
25
(1/1/97)
20
(1/1/98)
Table 5
(Cant)
Table of Standards
(Phase II)
Percent Volatile Organic Compounds Weight
froduct Category 1/1/95
Future
Effective
~
Laundry Starch Products 5
Personal Fragrance Products
Aftershave/Body Splashes 60
Colognes, Toilet Water,
Perfumes 70**
All Other Personal Fragrance
Products 50
* Effective January 1, 1993, no person shall sell, supply, or offer
for sale, or manufacture for sale in California any charcoal lighter
material without the written approval from the Executive Officer and
without a demonstration to the satisfaction of the Executive Officer
that the vac emissions resulting form the ignition af charcoal with
the charcoal lighter material are less than or equal to 0002 pound
of vac per startc
**The standard for colognes. toilet water and perfumes only applies to
new products introduced after the effective date of the regulation~
one year period has been provided for retailers and suppliers to
I’sell through!1 products manufactured prior to the earliest effective date of
the standardB In order to ensure that the sell through provision can be
effectively enforced, the sell through period is not available for products
that do not display the manufactured date of the product~ or~ a code
indicating such a dateo
The effective date for products that are registered under FIFRA is one
year after the date listed in the Table of Standardso FIFRA and state law
requires that pesticide products be registered with the UoS~ EPA and the
California Department of Pesticides Regulation~ The registration process
requires companies to provide test results that demonstrate the safety and
efficacy of new or reformulated products& This provision allows additional
time for companies to register products reformulated for compliancee With
this additional year for compliance, products SUbject to FIFRA requirements
will have five years to come into compliancee
Effective January 1, 1993, any consumer product listed in the Table of
Standards that is sold or manufactured in California cannot contain any
ozone depleting compounds regulated by the EPAo This provision will not
apply to any existing products sold and supplied prior to the effective date
of the standardso The requirements of the regulation will also not apply to
ozone dep’leting compounds appearing as impurities in amounts less or equal
to 0001 percent by weighto
29-
EMISSION REDUCTIONS
7he emission reductions realized from the aaoction of the proposed
standaras are 19~300 lb/oo A summary of the estimated emissions reductions
for each new category is shown in Table 10. ~mission reauct~ons range from
1 low of 280 lb/d for automotive brake cleaners to 9~600 f om lnsecticideso
Table 6
Summary of Proposed Standards and Emission reductions
2~..ea I ~1JIt1J,.aE\ I ?~.. , lM.:td..lU0I.l&J., l
S~ l RcIlGaC1:l.CUUU s~ t r:a1′-1GIl \
wt .. voc, :11.’;dAyo \ ift’ Vf.1C l’ RMtIIe:c.1OIIYI’
(1111’5′ I I (1/1/”1 ~’day
! \
1_410
i
\.urallo.l Cook1Dq sprays
~–”"”"‘-”"”‘———”"”"”"”‘—-4—-”"”"”‘—–~=–_~.-~J
\ AatC3Ct1.vGI 8rUa Cl.~
I
f~=——————————~”=’”"”"”
~
(~~C041 Liqb.tar Kat.r1″.l~
(Ytt.4U:.ly Averaq.,
:., &20
\carnurator Chok. Cleaners I i
\
740 J~JOa -.,~ 6&CD SO
! \
1
i
Di,lJ1.:o.teet:.&D1:.t8 — “eroaol. ~f600 .,0 1,340
AJ.d.a “‘”
AAurallol lJ.a 35 110 \ 25 22.
All Other rorIUI 20 “7 20
I – ~
I
Prot.~t. 4..0 :’3 600 I 1)41 ..00
!lAnd Oiab.v••EU..J1q Ocrt.lIlrqent:. 900 “. 4eo 1
! I !
~ou••no~ Adh••1Y••
lv.arctlo.l
til. Other Form..
‘~40
~,520
I
r I
~OI1/1/”"1
l,Za
1 19 200
HH3
~,lOO
::1!tl
:s~
70
50
.,000
.0
~,’40
1100
:_000
2,’00
720
3,,0.0
:’,400
I
I
I
I~La-l1l’1ld.r-.T.–. ft&rc.tl—ft’odII–crt-.——-+–3….”………O…-O-…..;….,-…..–………,.,,~-~-~”‘==MO 1
Ihn-.L~6·=C::~M. 1.120 60 ~~@I
Co.loq1Mlle” -roU.to WAter ,
~.
.u.1. ~
\
Ixn••cticid•• -crawLinq 8uq
Flea • .ad Tick
Fly1.luJ InlulC’C
….Fo9IpJ.na ‘~
L-. ., GafttClUl
ll.1 othllrll
U’J'U.L ‘ 5_7…..O_O_O_…ti )«JOO
-30-
When the emissions reductions from Phase II are combined w1th the
emissions reductions from the previousiy adopted consumer product
regulations the combined total is estimated at 118.300 lbs/day or 60 T/Do
This represents approxlmately a 30 percent reduction in consumer Droduct
‘~rn; ss ion s ”
Table 7
Total VOC Emissions Reduction from All Consumer Product Regulations
Emission Reduction
lbs/day
1993
1994
1995
1996
1997
1998
53,000
12,000
16,000
9,000
3,300
25,000
Total: 118,300 lbs/dav
(60 T/ D) ,~
-31-
.. !’~ETHODS OF COMPLYING ~ITH THE STANDARDS
Several methods are available to reformu”late products hat do not
urrently comply with the standards in the proposed regulation. The vae
solvents may be replaced in part or in whole with water or nother non=VO~
materialo The percentage of active ingredients, which in many ~ases are low
vapor pressure materials exempt from the voe standards, may be lncreased~
The VOC propellants may be replaced with a non-VQe alternative$ The product
form may be changed. Finally, the innovative product provision may be an
option for products that do not meet the vae standards, but result in lower
emissions than would be achieved through compliance with the standard, due
to some feature of the product.
One method of complying with the proposed vae standards is to replace
the voe solvents with water. This may be achieved by the creation of an
emulsion system or by changing to water compatible active ingredients. In
an emulsion system q two separate liquid phases are present with one phase
,j;spersed ‘in small droplets throughout the other “con tinuous phasell. In
~any consumer products, a water and solvent/oil phase are present, ~ith the
active ingredients dissolved in the solvent/oil phasee Often~ emulsifying
3gents, such as surfactants, are added to the formulation to facilitate the
mlxing of the two phases~ As an example, aerosol air fresheners may be
classified as single phase or dual phase systems~ The single phase air
fresheners are solvent based while the dual phase air fresheners are
typically emulsion systems with a water phase and a solvent phase which
contains the fragrancee The 1990 and 1991 consumer product surveys revealed
that the solvent based, nonemuls;on, aerosol air fresheners are nearly 100
percent vac, while the dual phase emulsion systems are typically in the
range of 30-35 percent voe, since water makes up one phaseo Water emulsion
complying products have been identified in many categories including dusting
sprays, insecticides, aerosol cooking sprays, carburetor and choke cleaners,
brake cleaners, and personal fragrance productse Manufacturers with
noncomplying products can very likely utilize emulsion technology to comply
with the regulationo
Another way to allow the reolacement of vac solvent with water ‘is to
use water compaiible active ingr~dientsa Some manufacturers may utilize
existing water compatible actives to develop complying productsa For
instance, insecticide products with active ingredients sensitive to water
may be reformulated with certain pyrethroids which are stable in water in
emulsion systemso Other manufacturers may have to develop water compatible
active ingredientso As an example, Kodak is in the process of developing a
hairspray resin that is soluble in demineralized water 9 in contrast to
current products which are soluble in ethanol (Eastman Kodak) ..
For products with active ingredients that are non-VOe or low vapor
pressure e~empt comounds, compliance may be achieved by increasing the
concentratlon of these lIact;vesll~ As an example, an adhesive may increase
~he content of nonvolatile polymers that form the bond after the solvents
nave evaporated ..
-32…
Aerosol proaucts wlth hyarocarcon (VOe) propellants may.be, aD~e to
educe their voe content by replacing the hydrocarbon propellant wlth a nonVOC
alternativeG For instance, if a product utilizes a oropellant only to
oispense the prodllct ingredients, and not for. its solvEmt nro pert;8s, .
mpressed gas propellants may be an alternatlve. Aerosol va~ve ~ec~nology
‘Jti 1;zing special nozzles or Ilmicro-tapli technology to malnt~ln conslstent
spray characteristics is currently avialable for products uSlng compressed
gases or compressed gas/hydrocarbon propellant blends (Aerosol Age, Deco .
1989 and Dec” 1990) (Surrrni t Va 1ve) . I n add; t i on ~ re aSE~arch and deve 1op~ent
efforts are currently underway to expand the application of this technology
(Summit Valve)~ Another option that has recently been utilized in a
hairspray product is the llAirsprayll system which is manually pumped by the
ooerator .. Yet another unique option is the l’Exxel lt system which uses a
rubber bladder to force out the product ingredientse
If the propellant must also function as a solvent, hydrofluorocarbon
(HFC) propellants may De an alternative to hydrocarbon propellants. HFC152a
is one possible alternative to hydrocarbon propellantso HFC-152a has a
moderately high vaoor pressure of 62 psig at 70 F and is a fair solvent with
a Kauri-Butanol (KB) value of II.. The KB value is a measure of a solvent’s
strength, v-lith higher KB vaiues representing lI stronger Jl solvents” HFC-152a
is relatively expensive at about $1,,75/1b, compared with less than $O,,30/1b
for hydrocarbon propellants (DuPont) .. HFC-152a is currently used alone or
blended with hydrocarbon propellants in hair mousse products and is
described as easy to work with from a formulation point of view (Johnsen)”
while production of HFC-152a ;s currently limited, capacity and consumption
are increasing (DuPont)” It is expected that the cost of HFC152a will be
reduced as production increases due to the marketplace economicso
Although in general the proposed regulation ;s not des’1gned to require
a product to change forms in order to meet the vae limits, this option is
available to manufacturers. Since most of the product standards include
different vac limits for different product forms, changing the form of the
product may provide a more favorable means of approaching the VOC limits for
an individual product.
Finally, the innovative product provls1on is available to products that
GO not meet the vae standards, yet result in less emissions due to some
feature of the product. Potential candidates for this provision include:
(1) products that deliver the active ingredients more efficiently, allowing
less product to be used; (2) products that contain more act<ive ingredients
or more effective active ingredients; and (3) products that emit vae
ingredients that are transformed to non-YQCso
Fm ADDITIONAL AMENDMENTS
The proposed amendments ‘include 72 new or revised definitions and the
deletion of 14 definitionSe Forty-three new definitions are being proposed
to be added to Section 94508. These new definitions are listed in Table
8D Of these, 17 are definitions for the new product categories being
~ . -.,,. . “””;ons ‘-do’eo ·\o.fi :ar~l ‘I ~,·.2rmjnoio.a.,Y ~rooasea Tor amendment and 20 are aeY nl~IJ a . L~ -
referencea in the regulation0
Definitions Proposed for Addition
Aerosol Cooking Spray
/~gricultural Use
All Other Forms
ASTM
Body Splash
Charcoal Lighter Material
Consumer
Crawling Bug Insecticide
Existing Product
Flying Bug Insecticide
Household Product
Insecticide Foggers
Lawn and Garden Insecticide
Non~Carbon Containing Compound
Person
Principal Display Panel(s)
Product Category
Responsible Party
Spray Buff Product
Toilet Water
Type B Propellent
Usage Instructions
,C\.”fter shalve
/4. 1lother Car’ bon – Can t a i n i n9
Compounds
Automotive Brake Cleaner
California Sales
Cologne
Container/Packaging
Device
Flea and Tick Insecticide
Hand Dishwashing Detergent
Insecticide
Label
LVP Compound
Perfume
Personal Fragrance Product
Product Brand Name
Product Form
Restricted Use Pesticide
Table B Compound
Type A Propellent
Type C Propellent
Wasp and Hornet Insecticide
Table 9 identifies the categories which were revised in the regulationa
Table 9
Definitions Proposed for Modification
/\eroso 1 Product
Automotive Windshield Washer Fluid
Carburetor – Choke Cleaner
Distributor
Fabric Protectant
Furniture Maintenance Product
Household Adhesive and Sealant
Institutional Product or
“Industrial and Institutional
(1&1) Product!!
Nonresilient Flooring
Pesticide
Pump Spray
Retail Outlet
Volatile Organic Compound
Wood Floor Wax
-34-
,~i r Fr’eshener
Bathroom ana Tile Cleaner
Disinfectant
Dusting Aid
Floor Polish or Wax
General Purpose Cleaner
Insect Repe i ‘lent
Laundry Starc~ Product
Liquid
Manufacturer”
Paint
Prope ’11 ant
Retailer
So 1i d
Wax
Tuble 10 identifies those categories that have bei~n ae!ete~” . lIe, ‘
categories were deleted because the category was no lon~er aopllcable ~othe
~egulation, was combined with another category, or has been postponed for
ans1deration”
Tab]e 10
Definitions Proposed for Deletion
Aerosol Food Product
Automotive Chrome Polish
Automotive Leather/Vinyl Cleaner
Brake Cleaner
Food
Household Pesticide
Lubricant
Water Proofing PrOducts
2″ .E xempt i OD.-S.
Automotive Bug and Tar Remover
Automotive Tire Dressing
Automotive wheel Cleaner
C1eane~r
Household Consumer
Industrial Spray Buff
Rug Deodorizer
Staff proposes to amend section 94515 IIExemptions li ~JY modifying the
exemption for fragrance and to add an exemption that would apply to cologne,
perfume, and toilet water ..
Fragrance: The voe standards, as adopted in 1990, do not apply to
fragrances and colorants up to a, combined level of 2 percent by weight
contained in any consumer product~ This exemption was established to allow
manufacturers a de m;n;mus level of these substances ‘in various products
such that the products may be marketed in an appealing manner to consumers~
Staff proposes that this exemption for fragrances and colorants be modified
by deleting colorants from the exemption and amending the exempted level to
’1 percent ..
The staff determined that a 2 percent exemption for fragrances may not
be aopropriate.. Based on telecommunications with colorant ~anufacturers
(BASF, Seltzer), it was revealed that colorants are solid compounds with low
vapor pressures and are, therefore, already exempt from the standards in the
regulation under section 94510(c)o Further review of formulations found in
industry trade journals and a report prepared for the New York state
Department of Environmental Conservation demonstrated that most consumer
products contain less than 1 percent fragranceo (Household & Personal
Products Industry) (Pacific Environmental SerVices) In addition to the
referenced sources above, staff also received information (Fragrance
Materials Association) which indicates that the level of fragrance used in
hair sprays, shaving cream, general purpose cleaners, laundry detergents,
and spray furniture polish ;s less than 1 percento
For products with a fragrance content greater th,in 1 percent, such as
some air fresheners and personal fragrance products, the fragrance content
-35-
:an e cons1derea an active ingredient of the proauct and is often present
n tne formulation at higher percentages. apP~olimatejy 1 o~. per~ent.for
ersonal fraarances, and 1 to 6 percent for alf freshenerso )lnce ~or these
oroducts the-fragrance is a significant part of the total voe, the ~ragrance
VOCs were taken into consideration in determining the proposed standards~
Cologne, perfume, ~nd Toilet Water: Proposed section 94510(h) would
~rovide an exemption from the vac standards for colognes. pe~fume~, or ~
toilet water formulations registered within 90 days of the etfectlve d~t~ of
the consumer products regulation as required under section 94513(a~. l~lS
would exclude existing perfume, cologne, and toilet water form~lat~ons from
the 70 percent voe standard specified in section 94509(a)o Whlle the
technology exists to produce these products at 70 percent vac as evidenced
by the 84 complying products currently available, staff recognlzes the
difficulties that would be encountered in reformulating existing products to
the proposed 70 percent standard while retaining the i~~~ scent~ New
productS 9 in contrast, should be able to be developed within the constraints
of the proposed 70 percent standarde This is further discussed in Chapter
‘-/1 I ~ I! Product Category I s sues Gil Wh i 1e staff recogn; zes the d ; ff ’1 cu 1ties “j n
~eformulating existing products, staff intends to continue evaluating
~echnolog;es available to the perfume industry and will reevaluate the need
or this provision in the future.
Paradichlorobenzene; The exemption for paradichlorobenzene (PDCB) has
been extended for moth-proofing products comprised of at least 98 percent
PDCB0 At this time, staff is unaware of suitable replacements for these
products (mothballs). Staff will continue to evaluate the appropriateness
of the exemptions for PDeS and will reconmend amendme~nts if further studies
demonstrate that the exemptions are unnecessary.
3~ Innovative Products
The primary change proposed for the innovative product provision is to
clarify the procedure by which emissions from an innctvative product are
compared to the emissions from a noncomplying product Ilhad it been
eformu 1ated II to camp 1y 0 The present prov; s; on a 11 O\VS a manufacturer to
demonstrate that a product is innovative in one of two wayso A product can
be “innovative l1 by (1) demonstrating that its vac emissions are less than
the emissions from a complying representative product or, (2) lI”if the
lnnovative product is a modification to an existing product ” , by showing
that the use of the product will result in less VOC emissions as compared to
the reductions in emissions that would have occurred from the exist ina
product had it been reformulated to meet the standards -
. Th~ problem with the existing version is that the language “if the
~nnovat~ve product is a modification to an eXisting product~ limits the
lnnovatlve product to modifications of existing products, if it chooses to
compare its emissions to a noncomplying product. This limitation is
unn:c~ss~~y and confusing, since it is difficult to distinguish between a
~odlflcatlan to an existing product and a completely new product. Language
I;as bee~ proposed.removing this r~striction and clarifying how the emissions
Trom a noncomplylng product had It been reformulated!! are to be determinedo
…. 36-
other oroooseo chances tJ the Innovative PrOductS l)rOVls;on I~cjude
correcting ‘inconsistent usage of the t.erms oIemlssionsli and 1l!~rniSS1~n
reduct i on s a ~ and add i ng 1anguaqe to sect ion (f), now proposE~d sect Ion (e),
which allows the Executive Officer to soeclfy terms and conditions necessary
to verify hat the requirements of the provision are met.
4~ Test MethQd~
Section 94515 is proposed for amendment to incorporate new test methods
for solids and charcoal lighter fluid~ The proposed test methods are ASTM
D~4359-90 Determination Whether a Material Is a Liquid or a Solid and South
Coast Air Quality Management District Rule 1174 Ignition Method Compliance
Certification Protocol, dated February 28, 1991.
The record keeping provision in this section is also proposed for
amendment to require that manufacturers maintain records for only those days
in which production occurred. Under existing language, manufacturers are
required to keep records even for days on which they did not produce any
products~ This amendment is designed to reduce the amount of records
required by a manufacturer 3nd to simplify the reporting process.
References:
I~eroso1 Age, lI~~i era-vapor tap improves C02 Performance., II AeLQ~e.,
December, 1989 ..
Aerosol Age, “Actuator button regulates container pressure,lt 8erQ~~L
~, December 1990″
1991 ARB Consumer Products voe Survey, sent to consumer product
manufacturers on March 12, 1991&
BASF, telephone conversation between ~ representative and
Tom Evanshek, September 3, 1991~
DuPont, telephone conversation with Paul MilkeY9 circa lO/1!91~
Eastman Kodak Co”‘ llEastman AQ Po lymers For \’4ater~,8ased Ha i r Spray, II
Publication No& CB=14A, December, 1990.
Fragrance Materials Association of the United States 9 personal
communication to Paul Milkey, July 10, 1990.
Haimov, Mitch, et al. 9 SCAQMD Source Testing and Monitorina Branch
“Emissions of Volatile Organic Compounds from Various Charcoal Ignition
Methods ll
, September 1990″
Household & Personal Products Industry, Formulary, Volume 3, 1988c
-37-
Jefere~C2S (cant):
~~ 0 hnson q ~1 0 nt for t ‘I I~”\. <\ ‘I The Flu 0 roc arb ans- Old fJ rob 1efn s 1’1 d t,l ew
GoP a r l: UiI 1tie s ~ II ~:\e[9 ~ Q] ~, 9e, \~ anua r y ~ .1 99 1 ·
Kenneay, -~im9 Clorox Company, resentation to A,RB staff” ~’v'larch 19,
1991.
Lieu(l Sue, SCAQMD r)lanning Divlsion, ill~ddendum IO Staff ~3port:
Socioeconomic Impact Assessment’! Proposed Rule 1174, Control of
Volatile Organic Compound Emissions from the Ignition of Barbecue
Charcoalu~ September 1990.
Marinoff, steven, South Coast AQMD Source Testing and Monitoring
Branch, Personal communication with Floyd Vergara, October 2, 1991.
Nielsen Marketing Research sales data for Californiao Jbmitted by T~m
ennedy to ARB on March 19, 1991.
Pacific Environmenta”1 Services, lI i\nalysis of Regu]ato~’/ ,L\lternatives
[Qr Controlljng volatile Organic Compound (vae) EmissjQUS Feorn C~~~C=
and CQrnmerc i a1 Products in the New York City Metro(JQ 'i=uan Ar~a II ,
January 17, 1990, Appendix E.
Perryman, Pame"ta, SCAQMD Office of Planning and Rules, tlStaff Report:
Proposed Rule 1174, Control of Volatile Organic Compound Emissions from
the Ignition of Barbecue Charcoal ll
, September 1990.
Seltzer, telephone conversation between Seltzer representative and
Tom Evashenk, September 3, 1991.
umm,t Packaging Systems. Inc.~ telephone conversation with
Paul Milkey, 10/1/91.
.IMPACTS ASSESSMENT
\~ ENVIRONMENTAL IMPACTS
The staff's procosal will limit the volatile organic compound content
or 12 new product categories~ The primary environmental impact will be a
decrease in VOC emissions to the environmente Because VOCs are involved in
the formation of tropospheric ozone, a reduction in VOC emissions is
expected to result in a positive impact on air quality and pUblic healtho
During the development of the proposed amendments, staff considered the
potential impact of the proposed amendments on the environments
Specifically, staff considered the potential impacts on stratospheric ozone
depletion, greenhouse warming, water pollution, landfill space, and toxic
air contaminants from implementation of the proposed amendments 0 As more
fully explained in the Technical Support Document, staff expect no
s'ignificant environmental impact from adoption of the proposed amendmentso
n addition, no adverse environmental impacts from implementation of the
Drooosed amendments have been identified with respect to earth, plant.
~nimal, noise level, and the use of land and natural resources.
The proposed amendments are expected to result in an overall reduction
~n vae emissions and a decrease in both ambient ozone and PMIO
concentrations. Due to the nature of consumer products, the emission
:eductions would be directly proportional to the population of each area in
the state.
80 ECONOMIC IMPACTS
The proposed regulation will require the reformulation of some products
in each categoryo However, for all the new product categories listed, there
are products on the market which can meet the standards proposed for
January 1, 19950 Staff performed an economic analysis to determine the
cost effectiveness of the proposed amendments $ Two separate analyses were
performed; one which assumed reformulated products will retain the same
product form; and one which assumed reformulation to a different product
-39-
,ormo ~or both analyses, staff assumed that new proauc s would be marketea
nationaily. Based o~ information from industry~ the rna orlty of consumer
product manufacturers market products nationally. Most of these comoanies
plan to market products reformulated for California nationally whenever
oossible.
For the first analysis~ staff assumed that product reformulation would
not require any major retooling or equipment changes since product forms
would stay the same. In addition, staff assumed that there would be no per
unit material cost increase and that marketing costs would be minimal. For
the second approach, staff assumed that the change in product form would
require a change in the delivery system~ This would require changes to
production equipment and/or delivery system of the productD Staff assumed
this would create additional costs due to personnel resources, packaging,
distribution, and warehousing. Staff also assumed that the new product form
would require additional marketing costs, research studies and tests,
promotional literature, and consumer testso
r3ased on the assumptions discussed above~ the staff estimate that the
cost to reformulate a non-complying product to meet the proposed regulations
will range from $76,000 to Sl~100,OOO. Annual cost estimates for
reformulating a single product range from $15,600 to $270,0000 The total
annual cost to industry is estimated to be between 13 and 205 million
dollarso
The results of these analyses were a cast·-effectiveness range from less
than $e01 per pound of VOC reduced for the lost cost anal is to $1e04 per
pound of VOC reduced for the high cost analysiso The range in the cost~
effectiveness estimates reflects the uncertainty in the cost to reformulate
the wide variety of products covered under the regulationo Table 11 shows a
comparison of the cost-effectiveness of the proposed amendments to other
measures that have been adopted in recent years. As shown in Table 11. the
cost effectiveness of the proposed regulation is within the ranqe of other
control measures adopted by the Board. ~
-40-
Ta.ble 11
Comparison of Cost-Effectiveness of the Proposed Amendments to
the Consumer Products Regulation with Cost-Effectiv~ness
of Other Control Measures for Criterla Pollutants
Architectural VOC
Coatings (1989)
Low Emission
Vehicles/Clean NOx, VOC, CO
Fuels (1990)
L 'j ght Duty
Diesel Exhaust PMIO
standards> (1987)
Heavy Duty
Diesel Exhaust PMIO
Standards (1985)
Deodorants &
Anti-perspirants vac
(1989)
Cost Effectiveness
($/ TQn Q f. P_Q lJJJ1~nt 0, e~~-;n)~
Net savings 12~800
lO,OOO~32?OOO
5 ~ 4a0 21 ~ .,:1. 00
6,400
Phase I Consumer
Products (1990)
Phase II Consumer
Products (1991)
voe
voc
Net 5av i ngs q leO
8-2~lOO
The economic impact of the proposed amendments on consumers is
difficult to assess as it would depend on many factors including consumer
preference, loyalty to a product, and the price of a producto Staff expects
that the cost of r~eformulation will be passed from the manufacturer to the
consumer~
Co SMALL BUSINESS IMPACTS
Staff evaluated the impact of the proposed amendments on small
businesses to determine if small businesses would experience significant
adverse economic impactso Based on a comparison of the return on ownerls
equity (ROE) before and after costs associated with the proposed amendments,
staff concluded that small businesses engaged in retailing and wholesaling
of consumer products and most small manufacturers would probably not be
adversely affected by the regulation~
-41-
EHASE I - FOllOW UP ISSUES
During the process of developing the consumer product regulation ~nd
the current proposed amendments~ ARB staff believe it has been responslve to
egitimate concerns raised by industry representatives a As a result,
staff's proposals have experienced numerous modifications and revisions
during the regulatory process. There are some issues, however, that likely
will remain and which are discussed in the next three chapters. In this
chapter, the staff discusses issues that were raised during Phase I and/or
that the Board requested additional investigation0
Ae SEll-THROUGH PERIOD FOR NON-COMPLYING PRODUCTS
This section addresses whether a one-year sell-through period for noncomplying
products is sufficient for the consumer products sUbject to this
regulation and whether special or additional sell through provisions are
needed for small businesseSa
At the October 1990 Board hearing, industry representatives testified
that a one-year sell-through period is not sufficient. The industry
~epresentatives requested using the date the product was manufactured to
determine compliance. They also requested, that if the date of manufacture
could not be used to determine compliance, a three year sell-through period
be allowed to avoid an unnecessary recall of products.
In response to the information presented by the staff and to the
industryls testimony, the Board adopted the one-year sell through periado
However, the Board requested the staff to 'investigate further whether
special or additional provisions are necessary for sma']l retail businesses
and to report back to the Board when amendments to the regulation are
submitted for the Boardls consideration in 1991~
In response to industry’s concerns and to the Boardls directive, the
staff conducted further research to determine if the one-year sell~through
period is sufficient for small businesses and businesses in generalo The
research included a re-evaluation and update of information gathered in 1990
and new data obtained from a retail business survey conducted by ARB staff
-42-
n 1991″ 8asea on this information” ~.he staff beiieves ene-year se’il
t. hr augh per; 0 dis suf f ; c i en t for all bus i nesse s, ‘j d r ge an (j Sfn ~ i 1″ ;; br ; ef
discussion of the information obtained by the staff to support the one~year
sell through period ;s given be’low~ .\ more deta,’ied sun1mar’y can be found in
the Technical Support Document.
1. Consumec Product Retail store Sucyey:
To implement the Board!s directive regarding whether onsideration of
special or additional provisions are necessary for smail retail businesses,
ARB staff conducted a survey of selected retail businesses in California”
Staff re’lied upon the definition for small business that ~s used by the
United states Small Business Administration (SBA) to provide the general
parameters for the consumer product retail store survey” According to SBA,
a II sma 11 In bus; ness is def i ned as one that i s independent 1y owned and
operated, not dominant in its field and meets employment or’ sales standards
developed by the agencY0 (13 Cede of Federal Regulations, section 121, Small
Business Size Regulations (1976) For the retail trade industry, the sales
standard is given as the average annual sales that do not exceed $ 3e5
million dollars for the preceding three fiscal years (up to $ 1305 million
dollars under some circumstances)e
The survey was designed to obtain representative data from retail
businesseso Using information from both the SBA and the County Business
Patterns 1988 (U@So Department of Commerce, 1990), staff developed a number
of questions that related to employees, annual gross sales, ownership and
sell~through period for products representative of those being regulated”
Although the SBA has established definitions on what is considered a II sma llu
business, staff developed the questions such that a further breakdown and
perhaps a more representative assessment of the type of “sma’il il businesses
that sell representative products can be obtained~
The survey form was sent to 4,000 retail businesses in California that
would most likely sell products sUbject to the regulation? ~ncluding
hardware stores: retail nurseries; lawn and garden supply stores; variety
stores; general merchandise stores; grocery stores; auto and home supply
stores; drug stores and liquor storeso
2~ Survey Results and Discussion
Of the 4,000 surveys mailed to retail businesses, 531 were completed
and returned to the ARB& Of the survey respondents~ 475 had sales less than
$3,,5 million per yearG For the product categories surveyed? (automotive,
personal care, pesticides, household, and miscellaneous), approximately
89 percent responded that the products were sold in less than 1 yearo As
shown in Figure 3, this data indicates that for all categories, a
proportionally higher number (89 percent) of the products were sold within 1
yearo
Although there was good correlation between the annual sales and sell~
through, no such correlation between annual sales and number of employees
-43-
~~8uld be aer1vea from t~ie survevo ,illS ~s not entir’2!Y unexoect:2dq ,;,<:ncc;
:here are numerous bUSlnesses ~nich altnouan they nave relatively ew
~mployees. nevertheless sell a signlficant-amouni of mercnanaise. -hus. r
‘_ 71 e pur p0 SeS 0 f t his dis cus s ion ~ s t af f ‘ri 1 11 lj set ~ e t er m ‘I inall bus i nes s ,I 1
elation to annual sales rather than t~e numoer of emoloyeesa
/’;ceo r din g torhe SBAdef ; n 1 t ion ~ ‘! sma 11I’ r- eta i 1 bus 1 nesse s donat :’<1 ave
~ore than $3G5 million dollars In annual saleso ~o be conservative and to
determine if a smaller annual sales definition is more acpropriate for this
analysis, taff looked at the sell-through perl0d for bUSlnesses with less
than $005 million dollars in annual saieso For these businesses, which
‘lnclude stores comnonly referred to as “mom and popu ~:tores, staff a1so
found that a proportionally higher number of products were sold within 1
year. As shown in Figure 4, 87 percent of the products in businesses with
tess than $OQ5 million dollars in annual sales were sold within 1 year, 10
oercent were sold within 2 years, 1 percent were sold within 3 years, and 2
percent were sold after 3 years.
3asea on the results from the retail survey and on our ~nderstandinq aT
~~e relationship cover1ng the aistribution of consumer prOducts. staff
nclude that the one year sell-througn is sufficient to allow for the
~emoval of noncomolying products from retail store shelves, including those
::;roducts in small businesses and so-called llmom and pop’J toreso
Typical Sell-Through Period
for Stores Having Sales Less Than $3,500,000
Air Resources Board
Retail Store Survey
.,,~~ ” ……..
// XJIIo…
// /’ ,.l~ ..
/
L
/ ~ /
/ ~, /
! ~/ r =-}~
’/
i ..,,r/
t:. 1<:1 r:I
\ –1
\ -I Y
\ l
‘\ /
‘\ )
”
20/ ,0
Less than 1 year
1–<-2
II 2-3
o r’v'lore Ulan 3 years
Figure 3
-44-
Typlcai Sell-Through Perioa .
for Stores Having Sales Less Than S500QOOO
Air Resources Board
Retail Store Survey
1°//0.
.— -x ~~ /,-
)(><x~ 2
,/ lI- ~T / \
/ • ,I.I /./
“/
r , 11
I ~ 1
Less ttlan 1 year
~J1ore tMan J years
Figure 4
B~ GLASS CLEANERS
Industry has requested that the SUbcategory “,~11 Other” F:orrrs Jl of glass
cleaner should be relabeled as ilLiquid/Pump Spraysll ‘in or”der~ ::J c1arify that
~he standardS are acplicable to liquid and pumo sorays. 2nd ~~at cloth
ioes ire not SUbject ~o any requlatory standard whatsoever.
he staff believes this cnange is unnecessary for the o11owlng
“‘~asons. irst~ cloth ‘lv·loe glass Cleaners are mere1y !iCUld (~”Iass c:eaners
‘~Dregnated into a cloth DacKaqe~ As such, the ARB has no 1~formation tJ
Indicate that cloth wipe cleaners cannot meet this reguiatory standardo
Secondly, even if cloth wipes cannot meet the standard. the regulation is
still technologica’ily and commercially feasible since over 80 percent of
urrently marketed glass cleaners ~lready comply with the proposed
standards,.
Finally, a few commenters have expressed the ‘/iew that ~n aoorov;ng
the Phase I regulation, the Board had intended to regulate Qnl1 I iqUld and
pump glass cleaner sprays. However, the rule making record demonstrates
that the Board did not intend to so limit the scope of the regulatory
standard. To clarify the Boardls intent for both glass cleaners and other
consumer product categories for which this term is used. the staff is
proDosing a definition for lI a ll other forms ll vlt’hich clarifies that wicks,
Dowaers, cloth or paper wipes~ etc~ are subject to the regulatory standards~
-·45-
Co BATHROOM AND TILE CLEANERS
Industry representatives commented at t71e .Oc~ober 1.1~ 990 hear1ng that
the 5 percent standard for aerosol bathroom and tl1e cleaners was not.
technologically feasible~ In its resolution ~dopti~g t~e ~onsumer prOducts
reaulation last year, the Board directed the Executlve Off1cer to gather
additional data on the feasibility of a 5 percent VOC standard for bathroom
and tile cleanerse
The 5 percent standard for bathroom and tile cleaners, including
aerosol bathroom ana tile cleaners, was set, in part? based on data from the
1990 Consumer Products Survey as supplied by Heiden and Associatese The
initial data supplied by Heiden showed that 5 aerosol bathroom and tile
cleaners complied with the 5 percent standarde Heiden and Associates
SUbsequently supplied the ARB with corrected data which listed one aerosol
bathroom and tile cleaner at or below the 5 percent standardo Data from the
most recent consumer products survey conducted by ARB lists no aerosol
bathroom and tile cleaners that comply with the 5 percent standarde
In response to the most recent survey data and further consultation
with manufacturers of bathroom and tile cleaners, staff are proposing a
7 percent standard for aerosol bathroom and tile cleanerso
D$ LAUNDRY PRE-WASH PRODUCTS
At the October 11, 1990 Hearing, the Board directed staff to examine
the feasibility of a 5 percent voe standard for laundry prewash products in
forms other than aerosols or solidso Staff reviewed current data on this
category and have determined that the limit is feasibleo
The majority of the emissions from laundry prewash is contributed from
the aerosol formso From the 1990 survey results, staff estimated that
emissions from aerosols accounted for 80 percent of total category
emissionso The survey also showed that the vac contents of aerosols and
solids are considerably higher than other formso Based on similar findings
from the previous survey, staff proposed two standards for the categoryo
The standard at 22 percent for aerosols and solids reflected low VOC
technology in those two product forms and should achieve emission reductions
from both formso The standard at 5 percent for all other forms was proposed
to llcapU voe contents for products such as liquids and pumps that are
a 1ready at low voe 1eve 1S e The II cap I s II pr imary purpose i s to prevent future
emission increasee Since the Ball other ll forms represent 80 percent of the
California sales, the increase of product VOC content up to a 22 percent
level from the current levels could represent a maximum of 10,000 lbs/day of
additional emissionse
vae emissions for aerosol products approximate the vac content because
propellants and other light hydrocarbon solvents readily volatilizee The
Reckitt and Colman company commented last year that the emissions of VOCs
from liquid products may not be significanto They cited results from a
study they conducted that showed that fabrics treated with liquid prewash
-46-
Jid not ~ave a significant welght loss after 3 minutes of exposur: to,airo
The staff believes that the observation of no weight loss In the fabrlc does
not Drove insignificant emissions& The simplistic grav~met~ic me~hod.used
in the studv did not account for any possible weight galn or the Tabrlc by
ather means-that would offset weight loss from vae emissions0 For examp~e.
if voe emissions from the application to the fabric and moisture adsorptlon
anto the fabric occur simultaneously, the weight from the adsorbed water,
which has a higher density than most VQCs, could offset the weight, loss from
VOC emissions~ The staff believes that gravimetric methods must also
include speciation analysis to accompiish a per compound lI mass balance;! to
interpret the basis for the weight changes or the lack thereofG
Althouah the relative emissions from liquid laundry prewasn is still in
question, staff believe this does not conflict with the regulatory intent of
the standard for Hall other U forms. The staff did not proj any emission
reductions from the standard for· ” a ll others U
, which includes liquid laundry
prewash& The standard was set to prevent the shifting of emissions from
aerosol and solid forms into the lI a ll others ll forms .. ;\n examp’ie of this -is
that the standard will not allow increased use of vac in liquid and pump
products that may be much more volatile than the glycol ether that is in the
prewash products used in the Reckitt Colman experimentQ
The staff believe that the 5 percent standard for lI a ll other” forms of
laundry prewash should be retained, and that it is commercially and
technologically feasible. The 1990 survey results show that over 94 percent
of the market already complies with this standarde The complying products
span the household as well as the institutional and industrial marketso
to CHARCOAL LIGHTER MATERIALS
In ARB Resolution 90-60 (dated October 11, 1990), he Board directed
the Executive Officer to analyze the voe emissions from char~coal lighter
fluids as follows:
USE IT FURTHER RESOLVED that the Board directs tr,e Executive
Officer to survey the amount of vac emissions from charcoal
lighter fluid in the state. and to report to the Board in 1991
on whether it may be appropriate to adopt a regulatory standard
for charcoal lighter fluid .. 11
AR~ s~aff has complied with the Boardls request and has surveyed the vac
emlSS10ns from charcoal ‘lighter fluids and evaluated the feasibility of
reducing these emissions .. As discussed in more detail in the Technical
Support Document, staff have drawn the following conclusions from this
analysis:
Ie A year-round average (uncorrected for seasonal variation) of
approximately 28,000 lbs/day of charcoal lighter fluid is used
in California (1991 ARB vac Survey; Nielsen) .. Because the
product is incompletely combusted or otherwlse evaporates to a
certain degree prior to combustion, approximately 20 percent
of.the p~oduct used, or about 5,600 lbs/day, is actually
emltted lnto the atmosphere statewide (Marinoff; Kennedy) ..
-47-
. Assuming that the majorlty of charcoal barbe~uing occurs
between May and October, ARB staff estimate that peaK sunrner
voe emissions for this category are about 11~200 lbs/day
statewide (Perryman)e Unlike other product categories,
barbecu i ng , i s e’xpected to be a seasona I act i V”l t y. Thus”. the
peak summer emission estimate may be a more accurate estlmate
of vae emissions which would impact attainment with applicable
air quality standards more than a yearly average emission
estimatso
30 Staff estimate that the emissions from this category will be
reduced by approximately 30 percent, resulting in
1,700 lbs/day reductions (yearly average) and 3,200 lbs/day
reductions (peak summer average).
40 Clorox Company representatives have submitted data which
indicate that changing the formulation (i.80 9 various
petroleum fractions) to minimize emissions can be accomplished
(Kennedy)o This was supported earlier this year with the
announcement that a successful reformulation of the Kingsford
Lighter Fluid passed the SCAQMD Rule 1174 limit of 0002 pound
VOC per start”
50 The SCAQMD has conducted the major laboratory testing and
regulatory development for this product category in developing
their Rule 1174. To maintain statewide consistency, ARB
staffBs proposed standard and regulatory requirements for
charcoal lighter fluids are designed to be equivalent with
their counterparts in SCAQMD Rule 11740
Because charcoal lighter fluids complying with the SCAQMD’s Rule 1174
are now available, staff is proposing charcoal lighter fluid limits
onsistent with SCAQMD Rule 1174 .
. eferences:
1991 ARB Consumer Products vac Survey, sent to consumer product
manufacturers on March 12~ 1991.
Nielsen Marketing Research sales data for California, submitted by Tim
Kennedy to ARB on March 19, 1991.
Marinoff, Steven, South Coast AQMD Source Testing and Monitoring
Branch, Personal communication with Floyd Vergara, October 2, 1991~
Kennedy, Tim, Clorox Company, Presentation to ARB staff, March 19,
19910
Perryman, Pamela, SCAQMD Office of Planning and Rules? “Staff Report:
Proposed Rule 1174, Control of Volatile Organic Compound Emissions
from the Ignition of Barbecue Charcoal”, September 19900
-48-
VI.
GENERAL ISSUES
AG ENVIRONMENTAL PATHS OF vac EMISSIONS TO THE ATMOSPHERE
Many consumer products are used indoors and questions have been raised
regarding whether or not these emissions reach the outdoor or ambient airo
While it is widely recognized that ventilation of indoor areas and the
normal infiltration of air into indoor areas, result in indoor emissions
reaching the ambient air the staff reviewed the current literature to
further investigate regarding this premisee Based on the ‘information
available, the staff has concluded that, with time, VOCs that are emitted to
the indoor air, will migrate to the outdoor air and be available to
participate in the photochemical reactions that result in ozoneo A brief
discussion of this subject is presented belowG
10 Indoor VSo Outdoor Emissions:
voe emissions from consumer products must reach the ambient air before
they are available for participation in the reactions that lead to ozone
formationo The VOCs in consumer products may reach the ambient air by a
number of routes, depE!nding on a variety of factors such as the chemical
composition of the product, product usage, the location of usage, and the
ambient conditions (e~ge temperature, air flow, humidity)o
When consumer products such as charcoal lighter fluids, insect
repellants, and automotive products are used outdoors or in well ventilated
areas such as a garage or bathroom with an exhaust fan, VOCs are provided a
direct route to the ambient air after they have vaporizedo There are some
oppar tun i tiesin the SE! cas es for i nt era c t ion wit h sur f ace s (U S ; nk s II ), wh ; ch
will be described in more detail below. However, in general, these effects
are less pronounced than in enclosed indoor environments where vapors have a
less direct path to the ambient air.
Indoor emissions of VOCs from consumer products escape to the
atmosphere through thE! infiltration/diffusion of indoor air with outdoor air
in what will be referred to as air exchange. Prior to transport to the
ambient air, however, there may be other processes that can occur~ These
-49-
: an c e S 1mp i i fie d ~ 11tot he f:, ur ~ r [) ce ssesees cr 1 bed una e r ":. d a a r
:::~:1 iss 1 0 ns ,I •
ndoor Emissions:
ndaaremiss ion S 0 f \J aCs from con sume r r= rOd uc t sean r" e acnthe
atmosphere by a variety of mecnanlsms. he followlnq ca~es represent the ,
primary routes to the atmospnere: (a) gaseous or vapor pnase compou~as reacn
the ambient air with air exchange; (b) liquid VOCs evaporate over ~lme and
3xit wlth air exchanae; and (c\ gaseous VOCs are adsorced on surfaces ana
subsequently oesorbed and reach the ambient air through air exchange .. These
cases are not meant to be mutually exclusiveo For instance, an aerosol
procellant, which is a gas at room temperature, may directly enter the
ambient air with air exchange and partially adsorb onto a surface then
subsequently desorb for transport to the ambient air.
The propellants used in aerosol products such as isobutane, propane,
dimethyl ether, and partially halogenated chlorofluorocarbons such as HCFC
442b. HCFC-22, and HFC-152a are gases at room temperature. These gases are
emitted when an aerosol oroduct is sprayed and are 'immeaiate-Iy availab'le for
r erno val as a bu i 1din 9 l s '; ndaar a; r i s e~ chan ged \.y i thout doC) r '3 i r 0 Hi 9h "Y
\/ 0 1atil eli qui dsand produet s del; veredin a f; nem; st may a 1sobe
immediately available for transport to the ambient air through air exchange.
In these cases, transport to the outdoor air will be a function of the
exchange rate ..
The air exchange rate, corrrnonly expressed in air changes per hour
(ACH), is a measure of the rate at which indoor and outdoor air are
exchanged and will be a function of the heating and ventilation system in
the house or building, as well as openings such as windows and doors. Most
(lOUSeS in California would be expected to have infiltration r-ates betwef.~n
about 0.5 and 1.5 ACH, althougn in houses which have been sealed tightly to
conserve energy, the rate may be as low as 0.2 ACH (NCR). IOC emissions
~ill be transported to the ambient air ~ore quickly with hiqh infiltration
~- ates 0
(b) Liquid YOCs E~apQ[ate Over Time and Exit witb~Air ~x~~~
Liquid VOCs such as the solvents in consumer products must evaporate
before they can be transported to the ambient air by air exchangea Liquids
will continue to evaporate until an equilibrium is reached between the
liquid and vapor phaseso Since, the amounts of liquid will be small
compared to the volume of virtually any indoor area and since vapor ;s
continually removed due to air exchange, the liquid will cont~nue to
evaporate until it is gone. The rate of evaporation will be a function of
many factors such as the vapor pressure of the individual chemical
components and their interaction with each other, temperature, and the air
~xchange rateo Increases in temoerature and air exchange rate will increase
the rate at which a liquid will evaporate. After evaporation occurs, the
-50-
"a0 a r s '('/' ill bet;, a ns ;: 0 r ted tot ~1 e dmD 1 e nt c: I r \i i a the -.<
:]lScuSSed above ..
xcnanqe cS
(c) yacs ar~ Adsorbed on Surfaces and Subsequent L:L=~2~SQrbed ~~
Transported thI…Qugb Ai r Exchange:
3efore being transported to the amoient alr, IDCs may oe adsorbed onto
surfaces such as walls, carpets, and furniture. These surfaces are known as
:lsinks ll
• Studies have shown that organic vapors adsorbed by sinks are
reemitted. In a stUdy by Tichenor, samples of giass~ cel1ing tile, carpet,
painted wallboard, and upholstery were exposed to concentrations ~f va~or
phase organic comoQunds in a test chamber. The chamber was supplled wlth
clean air at the rate of 1 air change per hour (ACH) until the start of the
test when part of the clean air flow was replaced by a flow containing the
test organic vapor, during which adsorption occurredo After 48 hours, the
flow containing the test organic vapor was replaced with clean air, starting
the desorption phase of the test .. The stUdy showed that I’common indoor
materials were found to adsorb and subsequently re-emit vaDor phase organic
“:omoQunds II (T i chenor ‘I et .. a 1.. ) . After desorpt i on has cccurr’ed, \/01 at; 1e
Jrganics ar~ available for tr~nsport to the ambient 21r via air exchange ..
(d) ~b~rnlcal Reactions TCgosform VOCs;
In some cases, VOCs may be involved in chemical reactions which alter
their composition.. Depending on the chemical reaction, the VOC reactants
may be converted to non-VaC materials or different VOCSe These effects have
been considered during the development of the consumer products regulation~
As an example, some adhesives contain VOCs that undergo a chemical
reaction upon exposure to air or moisture~ For instance~ cyanoacrylate
adhesives polymerize on exposure to moisture on the surface of the
substance, transforming most of the VOCs in these products :0 a nonvolatile
’71aterialo ,L\nother example is the lIdown-the-drainll productso Depending on
the chemical compounds and the use of the product, some of the VOCs in
products such as laundry detergents and hand dishwashing soaos may be
biodegraded by microorganisms in the sewer system or wastewater treatment
acility. A more detailed discussion of this sUbject may be found in the
IlIssues ll section of the Technical Support Documente
B~ CONSUMER PRODUCT EFFICACY
The issue has been raised that the efficacy of reformulated products
will be less than that of the existing unon-comp’lyingll products and
therefore, consumers will use more of the reformulated products and voe
emissions may actually increase~
What is product efficacy and how is it defined? To define product
efficacy ;s not a simple task.. According to CSMA liThe lefficacyl of most
consumer products consists not just of a single measurable factor, but of a
number of factors, some but not all of which can be quantitatively and
linearly measured and comparedo. 0 .For some products, there are standard
quantitative industry methods for evaluating some of these factors, but in
-51-
most cases there are none, only proprietary methodologies develo~ed and
:’mployed by individual manufacturers. U(CSMA. 1991) Another manufacturer
states llMost rnanufacturers consider their test methods pro~rletary . Ii
information and part of their competitive advantage over other compan,e~e
(Procter &Gamble, 1991) Other manufacturers believe that the produ~t wlth
the greatest consumer acceptance (e.g. highest market share) determlnes the
efficacy for a particular product category or that consumerls .. p~rchase
decisions are the ultimate and unappealable test of product efflcacye
Relying on consumer acceptance may be one indication ttlat a product is
efficacious, however, there are many other factors that influence a
consumerls buying decisiono Consumerls buying habits are often influenced
by such factors as product marketing, advertising, cost, promotions,
fragrance, and product convenience; therefore, consumer acceptance alone
wou’ld not necessarily demonstrate product efficacyo A market leader is not
the market leader only because of product performance testing that is
conducted in the company laboratory, but is a function of many factors~
Since there are often no industry accepted standards on which to
evaluate the efficacy of reformulated products, the staff must rely upon the
information provided in the ARB consumer product survey and information
provided by consumer product manufacturerso The staff believe that the
reformulated products will be at least as efficacious as existing productso
There are a number of existing products that already meet the proposed
standards and that, combined, have sufficient commercial presence to
demonstrate consumer acceptanceo The staff believes that this is strong
evidence that it ;s possible to reformulate non-complying products without
sacrificing efficacye In addition, an inefficacious reformulated product
will likely fail in the marketplace and therefore not result in a
significant increase in vae emissions due to increased usageo
Ce TOXIC AIR CONTAMINANTS
Toxic air contaminants are not addressed in this Consumer Products
Regulation& However, manufacturers need to be aware that restrictions may
be placed on these compounds in the futureo When products are reformulated
to comply with the Consumer Products Regulation, manufacturers should be
aware that there is an economic risk associated with replacing volatile
organic compounds (VQCs) with compounds that have been identifed as TACs or
are scheduled for review in the futureo These manufacturers may face the
need to reformulate again in the future to replace the toxic air
contaminantso The ARB staff will do its best to apprise manufacturers of
regulatory plans so manufacturers can make sound business decisionso
Toxic air contaminants (TACs) are identified under the AB 1807 process&
Under this process, the Air Resources Board and the Office of Environmental
Health Hazard Assessment develop a comprehensive report on the health risk
associated with a compounde After public review and comment, the report is
then submitted to the Scientific Review Panel (SRP), a pane’) of experts in
var;~us scientific f~eldso The final decsion regarding the listing of a
~andl~a~e s~bstance 15 made by the Board at a public hearingo After
ldentlflcat,on as a toxic air contaminant, the control phase begins$ During
this phase, sources of TACs are evaluated for consideration for control If
found appropriate, control measures are developed by staff and are submitted
to the ARB for consideration for adoption into the California Code of
Regulations.
Currently, there are sixteen substances that have been identifed as
toxic air contaminants. These substances are listed in Table 12 below.
Table 12
Toxic Air Contaminants
Asbestos
Benzene
Cadmium (metallic cadmium
and cadmium compounds)
Carbon tetrachloride
Chlorinated dioxins and
dibenzofurans (15 species)
Chloroform
Chromium VI
Ethylene dibromide
Ethylene dichloride
Ethylene oxide
Inorganic Arsenic
Methylene chloride
Nickel and nickel compounds
Perchloroethylene
Trichloroethylene
Vinyl chloride
Among the substances that may be of concern to consumer product
manufacturers, are methylene chloride and perchloroethylene both which have
been identified as TACs and are used in some consumer products, particularly
the automotive care productse
References:
Chemical Specialties Manufacturers Association (CSMA), Letter of July
23, 1991, pp. 29-30.
National Research Counc; 1 (NCR), (1981), Indoor pollutanli, National
Academy Press, Washington. D.C.
The Procter &Gamble Company, Letter of July 26, 1991.
Tichenor, Bruce A., Zhishi Guo, Dunn, James E., Sparks, Leslie E.,
Mason, Mark A. (1991) liThe Interaction of Vapour Phase Organic
Compounds with Indoor Sinks,1I Indoor Air, Vol. 1, pp. 23-25.
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VII.
PRODUCT CATEGORY ISSUES
A. l,l,l,-TRICHLOROETHANE
Title VI of the Federal Clean Air Act (FCAA) requires the phase-out of
production of class I and II stratospheric ozone depleting compounds (DOC).
Class I compounds are substances that have the highest ozone-depletion
potential (OOP), a measure of the relative ability of a compound to deplete
the stratospheric ozone layer. Class II ODCs are any other substances that
the EPA determines or anticipates to contribute to the depletion of the
stratospheric ozone layer. Title VI also requires that the production of
1,1,1-tri~hloroethane (TeA), a class I compound, be terminated by January 1,
2002. However, limited production of TCA for essential use can be allowed
to continue until January 1, 2005, if the EPA determines that such allowance
;s necessary and is consistent with the Montreal Protocol. The phase-out of
TCA begins in 1993, and gradually progressive cuts in product~on levels will
be implemented until production is terminated. TeA is a compound that,
under the definition of VQC, is considered to be negligibly photochemically
reactive. Since there are many products that use TCA its phase-out may
have a significant impact on consumer product manufacturers and the
potential exists, that if manufacturers replace TCA with YOCs, the emissions
of VOCs may increase.
1. How Extensiyely is TCA Utilized in Consumer Products?
TeA is used extensively in automotive, institutional and industrial,
and household aerosol products. An estimate of domestic consumption of TeA
in aerosol use shows that in 1987 approximately 25 million pounds are used
in automotive and industrial products and approximately 14 million pounds
are used in household products. (IeF) TCA is used in aerosol products
because of advantages such as non-flammability, high stability, adequate
solvency, low surface tension and viscosity for forming small droplets, and
high evaporation rate. (ICF) Products reported in the ARB survey that
significantly utilize TeA account for approximately 5 million pounds per
year of TCA emissions. These products are brake cleaners, carburetor choke
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cleaners, lubr;cants~ insecticide foggers, waso and hornet insecticides,
fabric protectants, and spot and stain removers. ihe staff estimated the
TCA emissions for these products by adjusting the total exempt solvent
content summed from the ARB survey, to the average TeA content in these
products. For example, staff multiplied the total exempt solvent content
for brake cleaners by 80 percent to obtain the TeA emissions because the
average exempt solvent content in this product comprises of 80 percent TeA
and 20 percent methylene chloride.
2. Will TeA be Phased-out early?
Sections 606, 608, and 610 in Title VI of the FCAA give EPA the
authority to implement early phase-out of DOCs. The staff discussed with
EPA’s Division of GlObal Change the legislative intent and the regulatory
plans for these sections. According to EPAls current interpretation of the
FCAA, section 606 gives EPA a broad authority to accelerate the phase-out
schedule of any class I and class II ODCs. However, EPA is to implement
such actions only if significant scientific evidence shows that the schedule
acceleration ;s needed to protect human health and the environment, or if
the Montreal Protocol phase-out schedule is modified to be more stringent
than the FCAA. The EPA staff believes that section 606 authority will
unlikely be applied to TeA because it ;s a relatively low OOP class I
compound, and no new data suggests that it may be more harmful than
currently believed. In addition, the likelyhood that the Montreal Protocol
phase-out schedule for TeA will become more stringent than the FCAA ;s
small, especially when the FCAA ;s currently the more stringent of the two.
Section 608 does not apply to TeA because it addresses mainly the use,
disposal and recycling of ODe in household appliances and industrial
refrigeration processes. Section 610 does not apply to TeA because it
addresses non-essential uses. Regulation for section 610 will be adopted in
1991 to ban hydrochloroflurocarbon use in products such as party streamers
and no; 5e horns. (EPA)
3. What is the potential Impact on voe emissions from TCA phase-out?
The total VOC emissions of products reported in the survey that
currently utilize TCA is approximately 7 million pounds per year. If TeA is
replaced with vac at a 1 to 1 ratio, the emissions from these products could
increase by 5 million pounds per year or 70 percent.
4. How will Proposed yac Standards Prevent Emissions Increase?
Results from the survey show that products in the JJTCA product ll
categories often include high vac and low voe content products that do not
utilize TCA or any other exempt solvents. For these categories, staff have
proposed vae standards that allow the “compliancell of those low VOC products
that do not contain TeA or any other exempt solvents. In the fabric
protectants category, the survey results do not show any low vac products
that do not contain exempt solvent. For this category, standards are
proposed at levels that industry has indicated to be the lowest product VOC
content that can be formulated without exempt solventso (3M) The staff
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believe that compliance with these standards will have dual impacts on voe
emissions. First, the standards will reduce vae emissions from products
having vae contents above the limit. Additionally, the standards will limit
the amount of VOC that can be used to rep “lace the TeA in II comp l iant tl TeA
containing products. This iimitation would therefore prevent significant
voe emission increases from cateqories with products that must be
reformulated to comply with the “rCA phase-out. This IIdual ll emission
reduction and emission limitation applies to Phase II categories of brake
cleaner, insecticide fogger, wasp and hornet insecticide, carburetor and
choke cleaner. The staff believes that both the proposed standards, which
are proposed at VOC levels that do not require the use of l,l,l-TCA to meet
the standard, and the provision that prohibits any new use of ozone
depleting compounds but allows for the continued use in existing products,
does not conflict with the TCA phase-out. The “no new use H provision for
DOC in this regulation precludes any increase in TeA use in new products.
The phase-out schedule, as mentioned earlier, will be gradual, giving
companies time to incorporate low vae technologies.
5. Are There Other Benefits to Substituting TeA with Low yac Alternatjyes’?
In the past, companies have replaced TCA with other solvent or waterbased
systems in order to reduce ingredient costs. (leF) With the phaseout,
companies are again forced to replace TCA. While some VOC replacements
such as hydrocarbon solvents and perchloroethylene (PERC) seem to be natural
candidates in terms of solvent properties, they present problems in terms of
health and safety risks.
One of the most important qualities that TeA provides for aerosol
formulations is non-flammability. This quality ;s especially crucial in
household products, where consequences from safety liabilities can be
tremendous and marketing of products with “extremely flarrmable ll labels is
undesirable. (Johnsen) In addition to being a safety hazard for the users,
flammability also impact warehouse safety and warehousing costs. With
strict standards defined in the National Fire Protection Association Code
30B, warehouses storing highly flammable vac content aerosols are required
to install expensive fire protection equipment or risk losing their
insurancee (Ortho) The replacement of TeA with a flammable vae can expose
companies and their products to all of the above risks and costs.
Replacement of TeA with PERC offers similar advantages in nonflammability.
However, PERC presents additional risks with its toxicity.
PERC has been listed by the Board as a toxic air contaminant. Similarly,
compounds found in aliphatic and aromatic solvents, such as hexane, toluene,
and xylene, are all hazardous air pollutants identified in the FCAAo
Concerns about the health, safety and environmental hazards with VOC
replacements for TCA have prompted many companies to seek or develop low vac
water-based alternatives. S.C. Johnson, the major marketer of insecticides
in the country,adopted a company policy to incorporate water-based
technology. The largest manufacturer of fabric protectants, 3M, has taken
the initiative to deve’lop low voe products in this category that have no
-56-
historical usage of water-based technologies. Industry representatives have
stated that aside from the health, safety, and environmental benefits, low
VOC water-based systems can also provide long term cost savings. (Ortho)
Companies utilizing water-based systems can lower ingredient cost and
decrease their reliance on the supply of petroleum based products.
The staff believe that the standards proposed for the TeA products in
Phase II is consistent with industry goals in the phase-out of TeA. We
believe that the standards will reduce voe emissions from current high vae
products, limit emission increases that may result from TeA phase-out, and
in addition proliferate technologies that bring about safer products for
consumers.
B. AEROSOL DISINFECTANTS
One manufacturer of aerosol disinfectants (L&F Products) has questioned
the need for and appropriateness of regulating disinfectants, especially
aerosol disinfectants. They have stated that these products provide an
invaluable health benefit to the public and should therefore be exempted
from the regulation.
Based on extensive consultation with infection control experts from the
California Department of Health Services (DHS), information obtained from
the 1991 ARB VOC and Hard-Surface Disinfectant Usage surveys, current
literature and advice from other infection control experts, the staff have
concluded that emissions from aerosol disinfectants can be reduced without
adversely affecting the supply of effective disinfectants for consumer use.
The staff’s analysis involved a review of the information obtained from the
sources described above and is summarized below; greater details regarding
these findings can be found in the Technical Support Document (TSD).
1. Why regulate the VOC content jn aerosol djsjnfectants?
The proposed requirements will affect only aerosol disinfectants. This
means that no adverse impacts should be felt by liquid, pump spray, solid
and other nonaerosol disinfectants. On a mass basis, nonaerosol
disinfectants comprise approximately 99 percent of the total combined
consumer and industrial/institutional (1&1) market, with aerosol
disinfectants comprising the remaining 1 percent. However, aerosol
disinfectants emit a disproportionately large percent of the emissions (40
percent) for the disinfectant category (1991 ARB VOC Survey) 0 While
reformulation of aerosol disinfectants is possible and can result in
emission reductions, there are few, if any, emission reductions available
from the nonaerosol products. Few reductions are possible from nonaerosol
disinfectants because the vast majority of these products are dilutable
concentrates. After the recommended dilution, these products generally have
very low vac content.
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staff1s research shows that aerosol disinfectants dominate only in the
consumer household market. This finding is supported by the 1991 ARB vac
and Hard-Surface Disinfectant Usage surveys, which show that the majority of
I&I consumers use liquid and solid disinfectants. Since these health care
facilities have very stringent disinfection requirements, it is reasonable
to assume that the nonaerosol disinfectants used by 1&1 consumers are
meeting or exceeding these stringent disinfection requirements. Thus, there
are low vac, readily available nonaerosol disinfectants which can meet
stringent disinfection requirements.
Staff1s extensive consultation with infection control experts from DHS
indicates that no adverse impacts on the effectiveness of aerosol
disinfectants are expected. This consultation, supported by information
obtained from the two surveys discussed previously and current literature on
infection control, indicates that current aerosol disinfectants can be
reformulated to meet the 60 percent vae by weight standard and still achieve
stringent hospital-level disinfection required by both I&I and household
consumers.
ARB staff estimates that aerosol disinfectants emit approximately 3.8
TID, with one product comprising approximately 95 percent of the total
emissions (1991 ARB vae Survey). Based on survey data, the proposed
standard of 60 percent voe by weight is expected to achieve a 25 percent
reduction in these emissions (1.0 TID).
2. How would the proposed standard affect the efficacy of aerosol
disjnfectants. especjally in regard to transmission of infectjous
diseases such as AIDS and jnfectious djarrhea?
The majority of aerosol disinfectants is based on a mixture of alcohol
(ethanol or isopropanol) with water and a secondary active ingredient (e.g.,
o-phenylphenol, quaternary ammonium compound) propelled by either a
liquefied hydrocarbon (isobutane, propane) or compressed gas (CO)
propellant. The alcohol, hydrocarbon propellant, and trace amou~ts of
fragrance comprise the product1s VOC. The amount of alcohol in existing
products ranges from about 20 to 80 percent by weight.
Standardized testing procedures for determining the effectiveness of
disinfectants are based on showing killing action against select target
organisms. For instance, a disinfectant that kills Staphylococcys ayreys,
Salmonella cboleraesyjs, Pseydonomas aeryginosa, Mycobacterium tubercylosis
~~, and Trycophyton mentagrophytes is rated as a fungicidal and
tUberculocidal hospital disinfectant (FIFRA). Disinfectants with this
rating are also known as lIintermediate-level ll disinfectants by the infection
control community (CDC). Nearly all alcohol-based aerosol disinfectants
have this rating, regardless of alcohol content. Intermediate- and lowlevel
disinfectants (i.e., hospital disinfectants without tuberculocidal
claims) are recommended by federal pUblic health agencies for preventing the
-58-
spread of Human Immunodeficieny Virus (HIV, the virus that causes AIDS) and
hepatitis-B virus (causes serum hepatitis) in health care workers (CDC).
Current literature demonstrates that most existing aerosol and liquid
disinfectants formulated with 60 percent by weight ethanol will provide
hospital-level disinfection with tuberculocidal and fungicidal activity.
Such disinfectants are implicitly considered to be effective against
virtually all vegetative bacteria and fungi and nearly all lipophilic and
hydrophilic viruses. However, for ethanol-based disinfectants, L&F Products
has raised the question of whether a 60 percent ethanol by weight
disinfectant can inactivate the group of hydrophilic viruses known as
picornaviruses. Picornav;ruses are a group of small (20-30 nanometers)
viruses which contain no lipids and which do not react with lipids (Block).
Such viruses include Polioviruses, Coxsackieviruses and Echoviruses.
Unfortunately, EPA has not selected a target organism for demonstrating
broad-spectrum virucidal activity. L&F Products, makers of Lysoi
Disinfectant Spray, claim that polio virus (type l)t because of its high
resistance to germicides, should be considered as a virucidal standard
(L&F). This is supported somewhat by recent (Rutala) and past studies
(Klein and Deforest; Christensen, R.P.). Since there is no existing
standard using polio virus, predictions of what level of vae will be
effective against polio virus are, of necessity, predicated on wel1documented
past studies.
After consultation with DHS infection control staff, ARB staff assumed
that polio virus is a reasonable standard to show efficacy against
hydrophilic viruses. With this in mind, staff reviewed current literature
to determine what levels of vac are necessary to inactivate this virus. To
date, studies conducted to determine germicidal effectiveness against this
virus have been conflicting. For example, both Klein and Christensen, in
testing ethanol-based disinfectants (with and without o-phenylphenol), show
that the minimum ethanol content required to inactivate the polio virus is
70 percent by volume (62 percent by weight). Other studies provided by L&F
Products indicate that 80 percent ethanol by wejght will definitely
inactivate polio virus, while 53 percent ethanol will definitely not work
against polio virus. Although the L&F data shows that 80 percent ethanol by
weight will work against polio virus, it does n2i conclusively show that 80
percent ethanol by weight is the minimum level required. Since 70 percent
ethanol by volume (62 percent by weight, as delivered) has been shown by
studies to inactivate polio virus, the standard of 60 percent vac by weight
in the can was chosen by staff to enable complying products to deliver a
spray onto the surface with 70 percent ethanol by volume, at a minimum.
According to the U.S. Bureau of Standards, 70 percent by volume ethanol
is equivalent to 62 percent ethanol by weight for the ljqujd fjlm on the
sprayed surface (USBS). Staff performed a propellant-loss analysis to show
that a 50 percent to 60 percent ethanol by weight aerosol disinfectant inthe
can, when sprayed, would concentrate to over 70% by volum~ after the
propellant fraction has flashed off and evaporated. Thus, a complying
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product with 60 percent vae in the can should be able to deliver a spray
with an effective level of ethanol.
Triangular diagrams are diagrams for three-component solutions which
can be used to predict selected physical properties of aerosol disinfectants
formulated to meet the standard. For example, according to readily
available triangular diagrams (Sanders), a single-phase aerosol disinfectant
at approximately 40 psig pressure could be formulated with 60%-10%-30%
(ethanol:water:HFC-152a) weight ratios (Figure 5, Point 5). HFC-152a is
used in this example because it is a non-VQe propellant which, when used in
this suggested formulation, will result in aerosol disinfectants with
moderate pressure (40 psig) and medium spray charateristics that are within
industry norms for this product. A product formulated in such a way is
expected to deliver, after propellant flashoff and evaporation, a
disinfectant liquid film to the sprayed surface with an estimated 85 percent
ethanol by weight (90 percent by volume). From the earlier discussion, it
is clear that this level of delivered ethanol ;s significantly higher than
the 62 percent ethanol by weight (70 percent by volume) that has been shown
by past and current studies to inactivate the polio virus.
Manufacturers have raised the point that ethanol would evaporate at a
faster rate when aerosolized; thus, a level of ethanol greater than 62
percent by wejght (70 percent by volume) is needed to account for additional
evaporation of ethanol. While staff agree that sufficient lI ex tra U ethanol
is needed to allow for a margin of error, staffls analysis shows that
sufficient allowance for error can be achieved while still complying with
the standard. To illustrate this, it must be noted that, given the same set
set of product and ambient conditions (e.g. droplet size distribution,
ambient temperature), the evaporation rate of ethanol in aerosolized
disinfectant dropiets is at a maximum when ~ ethanol, water and
propellants are contained in the aerosol product. However, existing aerosol
disinfectants employ several methods to reduce ethanol evaporation. Current
aerosol disinfectants such as Lysol Disinfectant Spray and Citrace Hospital
Disinfectant are required to provide germ-killing action for at least ten
minutes on the surface as stipulated by the EPA (AOAC). To stay viable on
the sprayed surface for ten minutes, these existing aerosol disinfectants
employ both a combination of a Il we t ll (medium to coarse droplets) spray along
with evaporation inhibitors to reduce the rate of evaporation of the ethanol
(Christensen). Since this technology is currently being used, staff fully
expects manufacturers to use the same technology to reduce the evaporation
of ethanol in complying aerosol disinfectants.
In addition, the complying formulation based on HFC-152a described
previously contains a significantly greater ethanol/water concentration (~
percent ethanol by wejght) than the 62 percent by weight shown to be
effective against polio virus. Because of this, it is reasonable to expect
t~a~ the high ethanol/water ratio (85 percent ethanol by weight) in the
dlsln~ectant con~entrate, in combination with the evaporation-reducing
t:c~nlques descrlbed above, should result in a complying aerosol
dlSlnfectant that will deliver a spray with sufficient allowance to account
for any droplet evaporation of ethanol that may occur.
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It snould be noted that the suggested formulation discussed aoove lS
~ot ~ntenaed to be the only possiole formulation for comPliance with a 60
percent voe by weight standard: it ;s merely intended to demonstrate that a
reformulation ;s possible. Depending on the choice of propellant blends.
desired soray characteristics. and ethanoi/water ratio, a manufacturer can
develoo other formulations which can also meet the vac stanaard while
Jroviding an ethanol oroauct with over 70 percent ethanol by volume. ;rom
this information, it appears that an aerosol disinfectant can be formulated
to have 60 percent by weight total vac in the can and still result in a 70
Dercent by volume ethanol prOduct 90 the sprayea surface. Since
disinfectants which deliver a product with 70 percent ethanol by volume have
been shown to inactivate polio virus and nearly all vegetative
microorganisms, it can be predicted that such a product would be effective
against most vegetative bacteria, pathogenic fung1 and viruses.
Based on the available information presented above and in the TSD, the
staff expects no adverse impacts on the effectiveness of aerosol
disinfectants. For example. it ;s well documented that the Human
:mmunodeficiency Virus (HIV), c~hich causes AcqUired ImmunoDeficiency
S,yndrome (AIDS), is a very fragi le virus outside of the human host. Levels
of ethanol much lower than those found in current aerosol disinfectants are
effective in killing this virus. Similarly, the staff expects no adverse
impacts on aerosol disinfectants· ability to inactivate fecal-oral viruses
such as rotavirus. Currently, there are aerosol and liquid disinfectants
with levels of ethanol below 60 percent by wejght which are registered with
FIFRA for rotavirus activity. Rotavirus is believed to be a major cause of
infectious diarrhea in young children (L&F).
Vapor Pressures of HFC-152a/Ethanol/Water Solutions at 70oF*
/,\’:Tf:ft
“~~\:O”POSITiONS IN
,/’ \ / \\N!:IGHT PERC!:N T
,!\, ,/ \ /\\
y\
,..:—-O~ASE 2QUNDARY ——..–
/ /
/ \
I …..,SCIBLE REGION
7′WO LIOUID PH ASES
~ISCI8L£ REGION!”.
L£ uaUiD
°MASE
ETHYL AL.COHOL
Figure 5
Reprinted from Sanders, Paul A. t Handbook of Aerosol Technology, 2nd Ed ••
p. 155.
-61-
~hy was 60 percent by wejght chosen as the standard for ~erosol
.d j S j nfectants?
,As explained above, 60 percent by weight I/Oe represents a level,:n
staff’s opinion, ‘Nhere emission reductions can be achievea without
compromising the product’s effectiveness. At 60 percent by weight vac, the
~RB VOC survey snows that 41 aerosol disinfectants would comoly. If the
stanaard were to appiy to nonaerosol d-isinfectants, virtually all of the
Jver 500 nonaerosol disinfectants in the survey would also comply after the
recommended dilution.
4. How can an aerosol disinfectant manufacturer comply with thjs standard?
As discussed previously, there are several ways a manufacturer can
comply with the standard such that the total yae content is at or below 60%
by weight: (1) formulate a proper balance of alcohol/water/propellant ratio
such that compliance is achieved while maintaining product integrity, (2)
shange propellant to non-VQe propellant such as HFC-152a, (4) increase the
amount of other active ingredients, such as the phenols ana/or quaternary
ammonium compounds, to achieve greater disinfection while allOWing a
reduction in voe content, (5) package the product into a pump spray, or (6)
;-edesign product into an innovative package such that it emits fewer
emissions.
5. How does staff provjde assurance that there wjll not be a health
problem from compljance with the standard?
In effect, the staff’s proposed standard challenges the industry to
maintain the current disease control benefits of aerosol disinfectants,
while reducing the contribution these products now make to Californials
serious air quality problems. The staff intends to recommend to the Board
that ARB and DHS staff jointly evaluate the progress and reasonable efforts
~ade by manufacturers in deve10ping viable and complying aerosol
disinfectants. In determining what possible impacts the standard may have
on the health benefits of these products, both ARB and DHS staff will
~valuate the effectiveness of products formulated to comply \~ith the
~tandard and achieve intermediate-level, hospital disinfection according to
the products j ability to kill or inactivate Staphylococcus aureus J
Salmonella cho]eraesuis, Pseudooomas aeruginosa, Mycobacterium tuberculosjs
Y..QL..~, Trycophytoo mentagrophytes, and any target organlsm or organisms
which the EPA determines by notice in the Federal Register as a generalpurpose
virucidal indicator(s) for showing activity against most hydrophilic
and/or lipophilic viruses. ARB and DHS staff will jointly report to the
Board on the progress of manufacturers in developing como lying products
~hich meet this criteria.
c. PERSONAL FRAGRANCE PRODUCTS
In the current proposed amendments to the regulation, ARB staff are
proposing to include vac limits for personal fragrance products. Industry
representatives have been very vocal about their opposition and claim that
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the standards being pracoseo are not technologically and commercially
reaslble, will adversely impact the retail business in Californla. stifle
creativity of a unique art form and should not be implemented since personal
fragrance products, as a category are responsible for de m1n;mus emissions
wnen compared to other products.
The staff believe it is appropriate to include standards ~~ the
regulation to achieve emission reductions from this category. It is
important to remember that individually many product categories in the
consumer product arena may have relatively smali emissions. ~owever when
considered in the aggregate the emissions are significant. The personai
fragrance category ;s not small when compared to other categories of
consumer products. Staff estimate the emissions from personal fragrance
prOducts to be close to 6 tons per day in California. Last year, the Board
established standards for several categories that had emissions less than
perfumes and colognes. Out of the 16 products regulated in Phase I, 13
products had emissions less than that of the emissions from personal
fragrance products being considered this year. To be able to achieve the
:lmaximum feasible Jl emission reductions required by iaw, it is necessary to
look at all categories – both large and small in terms of emlssions.
Section 41752 of Health and Safety Code require the Board to adopt
regulations that are technologically and commercially feasible. The current
staff proposal includes standards for personal fragrance products that staff
believe are technologically and commercially feasible. In recognition of
the concerns raised by industry regarding the ability to reformulate
existing products and maintain the identical scent, the staff ;s proposing,
at this time, to exclude from regulation all perfumes, colognes and toilet
waters that are already on the market and only require new perfumes,
colognes, and toilet waters to formulate to a 70 percent vae standard. This
exclusion for existing products reflects the fact that the staff believes
additional study and analysis of industry concerns is needed before
standards are proposed for existing perfumes, colognes, and toilet waters.
Standards may be proposed for the existing products at same future date if
further study indicates that standards are technologically and commercially
feasible. However, all aftershaves and body splash products 1 both existing
ind ~ew, would be required to meet a 60 percent vae stanaard. 3ased on our
survey there are already many products in the market place ~ that can
meet these standards. Change will be necessary – perfumers may need to
adjust the palette of fragrance oils that they use to focus more on those
that can tolerate higher levels of water, or may deliver the fragrance
product in a different form. This should not be viewed as a negative event,
however, since there are many ways to produce a fragrance product that is
pleasing to the olfactory senses.
The staff has held numerous meetings with the personal fragrance
industry associations and with some individual companies. During the time
in which this report was being finalized, the personal fragrance industry
brought a proposal to staff for consideration. The proposal addressed
industry concerns regarding the category definitions, proposed exemptions,
and proposed voe levels. The staff are evaluating the proposal and are
-63-
continuing to consult with reoresentatives from the cersonal fra ranee
industry. The staff will propose amenaments to the regulation 1 an
alternative approach can be develooed that will address lndustry s concerns
~nd meet the requirements of t~e California Clean Air Act~
~eferences
1991 ARB Consumer PrOduct VOC Survey, sent to consumer product
manufacturers on March :2, 1991.
1991 ARB Hard-Surface Disinfectant Usage Survey, sent to over 7000
health-care facilities on February 28, 1991.
3M Corporation, Presentation by 3M representatives to ARB staff during
CSMA household products task force meeting, July 15, 1991.
AOAC, Association of Official ,\nalytical Chemists Use Dilution Method
(AOAC UDM).
Block, Seymour S., Disinfect jon, Sterilization and Preservation, 3rd
Ed., Lea & Febiger, Philadelphia, 1983.
CDC, Centers for Disease Control (U.S. Department of Health and Human
Services), Guidelines ~Qr Prevention of Transmission of Human
Immunodeficjency Virus and Hepatitis B Virys to Health-Care and pub]jcSafety
Workers, February 1989.
Christensen, Rella P., et al., “Antimicrobial Activity of Environmental
Surface Disinfectants in the Absence and Presence of Bioburden,lI
Journal of the American Dental Association (JADA), Vol. 119, October
1989. EPA, Conversation between U.S. EPA Stratospheric Ozone Protection
Branch staff and ARB staff Peter Liu, August 25, 1991.
~IFRA, Federal Insecticide, ~ungJcide and Rodenticide Act. As Amended,
7 U.S.C., 136-136y. reF Incorporated, Use and Substitutes Analysis of Methyl ChlQroform
(l,l,l-Trichlocoetbane), February 14, 1989, VI-l to VI-47.
Johnsen, M.A., Aerosol Market Report by Montford A. Johnsen,
Commissioned by reF Incorporated. August 29, 19870
Klein M. and Deforest A., liThe Inactivation of Viruses by Germicides,1I
Soaps and Chemical Soecialties, 39:70-71, 1963.
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L&F Products (formerly Lehn and Fink Products), testimony and data
provided for the administrative record for the October 1990 ARB Board
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‘Jrtho_ Chevron Chemicai C:cmoanv. ,1~etina between Ortho reoresentat;ves
and ARB Staff, July 13. :391.
Prince, Herbert N., “Disinfectant Activity Against Bacteria ana
y i ruses: A H0 5 P; tal Gu i de II ,~,~ r t ~ :;:.: 1ate :; “1 d M; cr Q b j a ‘j CQ nt r Q ‘j J
Yarch/Apr i 1 1983.
Kutala, Dr. William, ~1fection cJntroi expert. University of North
Carolina, personal communnication with Floyd Vergara. September 16,
~991.
San der s, Pau 1 A., Han dboo k 0 f ,6 er 0 sol Tee hn0 log y , 2nd Ed., Rober t
Kr ; e ge r Pub 1ish i n9 Com0 any, 1~;1 a1abar, ;: lor ida, 1987 .
USBS, United States Bureau of stanaards Circular No. 19, values from
Tables 5 and 6.
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