The ISSA has submitted comments on the California Air Resources Board's (ARB) proposed new volatile organic compound (VOC) standards, citing their potential detrimental effect on the jan/san industry. Specifically, ISSA has raised concerns about various new labeling requirements, an amendment to the definition of a low vapor pressure VOC (LVP-VOC), changes to the reporting requirements, and, most notably, new VOC content limits for "general purpose removers," "adhesive removers," "graffiti removers," and "toilet/ urinal care products."
Concerned with the alleged likelihood that VOC emissions will increase in the near future, ARB proposed new VOC standards for 20 categories of consumer and institutional products. The new standards were borne out of the results of the 2001 Consumer & Commercial Products Survey and promise to have a significant impact on the formulation of numerous products in the industry.
Of most concern, ARB has proposed the following VOC content limits:
Adhesive Remover, General Purpose Remover and Graffiti Remover - 20%
Electronic Cleaner (Aerosol) - 25%
Electronic Cleaner (Non-Aerosol) - 5%
Toilet/ Urinal Care Product - 3%
Wood Cleaner (Aerosol) - 15%
Wood Cleaner (Non-Aerosol) - 1%
Further, ARB's proposal contains numerous amendments to the labeling and reporting requirements of the Consumer Products Regulation. Specifically, the proposal would require that the day, month, and year of manufacture be included on a product label and would prohibit the use of date codes; would amend the "most-restrictive limit" provision to apply to claims that appear anywhere on a product container (previously only those claims that appeared on the principal display panel would trigger the "most restrictive limit provision); would remove the "12 carbon atoms" criteria from the definition of an LVP-VOC; and would extend the reporting requirements to all companies involves in the supply chain.
The ISSA is extremely concerned about the new regulations and their potential effect on industry. Specifically, ISSA outlined the following concerns:
Requiring that the date of manufacture be included on all product labels will result in consumer confusion and will disrupt business processes.
The proposed amendment to the "most restrictive limit" provision will sacrifice safety and potentially place product users at risk.
Removal of the "12 carbon atom" criteria from the definition of an LVP-VOC eliminates an important tool used by chemists in determining whether a chemical compound qualifies as an LVP-VOC.
The expanded reporting requirements may interfere with established business relationships by requiring the disclosure of information by companies who are prohibited by contract from complying.
Holding water-based and solvent based remover products (including general purpose removers, adhesive removers, and graffiti removers) to the same VOC standard is inappropriate because they are dramatically different products with different uses.
The proposed VOC limit for remover products will essentially require manufacturers to replace solvent-based products with water-based products that may not be as effective or as cost-efficient.
A reactivity-based standard is more appropriate in regulating various categories of products and ARB should continue developing such a standard.
The proposed 3% VOC content limit for "toilet/ urinal care products" will essentially prohibit the use of paradichlorobenzene (PDCB), completely eliminating a product form.