Comment Log Display

Monday, September 23, 2013

Mary Nichols, Chair
California Air Resources Board
1001 I Street
Sacramento, CA 95912
Via web portal - http://www.arb.ca.gov/lispub/comm/bclist.php

RE:  	Proposed Amendments to the Aerosol Coating Products and the 
Consumer Products Regulations 

Dear Chair Nichols:

Ball Metal Food & Household Products appreciates the opportunity to
comment on the Proposed Amendments to the Aerosol Coating Products
and the Consumer Products Regulations scheduled for consideration
by the California Air Resources Board on September 26.   Ball
supports specific comments submitted by the American Coatings
Association and the Consumer Specialty Products Association on the
Proposed Amendments.

The consumer products industry has been actively engaged with the
California Air Resources Board since the promulgation of the
Consumer Products Regulation in the late 1980s.  Product
formulators expend countless hours and considerable amount of
research and development resources to reformulate products that
meet consumers’ needs and comply with the ARB’s stringent
regulatory standards.  We have worked collectively to achieve the
specific VOC limits by category to address air quality standards
and have invested hundreds of millions of dollars in research and
development to achieve these results.  

Ball Metal Food & Household Products appreciates the opportunity
for stakeholder input as the proposed regulation was developed. 
The Planning and Technical Support Division staff conducted several
public workshops and considered the technical input of stakeholders
in revising the proposed amendments to help ensure the final draft
achieved the required emissions reductions and does not compromise
the statutory requirements to ensure that proposals must be
technically and commercially feasible and does not eliminate any
product form.  

While the proposed regulatory provisions are technically
challenging for the industry to meet, we believe that the proposed
amendments are a reasonable approach to meeting the required
emissions reductions and we commit to expend the necessary time and
effort to meet these new regulatory standards.

Sincerely,

John J. Blum, Ph.D.
Director, Technical Services
Ball Metal Food & Household Products
1125 Gasket Drive
Elgin, IL 60120
Phone: 847.931.3956
Fax: 847.888.5649
E-Mail: jblum@ball.com
www.Ball.com