First Name | Sara |
---|---|
Last Name | Seidl |
Email Address | sara.seidl@ecolab.com |
Affiliation | Ecolab, Inc. |
Subject | Ecolab Comments to Proposed Amednments to the Consumer Products Regulations |
Comment | September 23, 2013 Clerk of the Board California Air Resources Board 1001 I Street Sacramento, CA 95912 via web portal - http://www.arb.ca.gov/lispub/comm/bclist.php Subject: Proposed Amendments to the Consumer Products Regulations Dear Clerk of the Board, Ecolab appreciates the opportunity to comment on the amendments to the Consumer Products regulation. These amendments are to be heard by the California Air Resources Board on September 26, 2013. A trusted partner at more than one million customer locations, Ecolab (ECL) is a global leader in water, hygiene and energy technologies and services that protect people and vital resources. With 41,000 associates, Ecolab delivers comprehensive solutions and on-site service to help ensure safe food, maintain clean environments, optimize water and energy use and improve operational efficiencies for customers in the food, healthcare, energy, hospitality and industrial markets in more than 170 countries around the world. Ecolab has the following comments. • Ecolab supports the addition of the definitions for Single Purpose Cleaner and Single Purpose Degreaser. Ecolab produces General Purpose products and Single purpose products. The addition of the definitions provides clarity to the regulation. • Ecolab supports the scientific pathway being taken by the staff in dealing with the Low Vapor Pressure (LVP) provision. LVP compounds are extremely important in maintaining compliance with current and future VOC limits. The LVP provision is needed to provide technical feasibility to the current VOC limits. In summary, Ecolab supports the amendments to the Consumer Product regulation. Thank you for your consideration to these comments. Any questions or comments feel free to call our consultant Doug Raymond at 440-474-4999 or at djraymond@reg-resources.com. Sincerely, Sara Seidl ASSOCIATE REGULATORY SPECIALIST I, LoG, CFIA, VOC ECOLAB 370 WABASHA STREET NORTH, ST. PAUL, MN 55102 T 651 293 4292 F 651 225 3122 E Sara.Seidl@ecolab.com Cc: Carla Takemoto, Air Resources Board Doug Raymond, Raymond Regulatory Resources (3R), LLC |
Attachment | www.arb.ca.gov/lists/com-attach/9-cp2013-AWRWM1U7AzxXMANh.pdf |
Original File Name | Ecolab Comments to Proposed Amendments to the CARB Consumer Products Regulations September 2013.pdf |
Date and Time Comment Was Submitted | 2013-09-23 09:27:20 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.