Comment Log Display

October 19, 2006


David Mallory, P.E.
Manager, Measures Development Section, Stationary Source Division
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812

Re: Unreasonable 10% VOC Standards for Automotive Maintenance
Products

Dear Mr. Mallory:

The Florida Chemical Company and its 45 employees are very
concerned about the Air Resources Board’s (ARB’s) 10 % VOC
emission standards for the four automotive maintenance product
categories in the proposed 2006 Amendments to California’s
Consumer Products Regulation.  

The proposed 10% VOC standard for Brake Cleaners, Carburetor or
Fuel-Injection Air Intake Cleaners, Engine Degreasers, and General
Purpose Degreasers will destroy the ability to manufacture
automotive maintenance products that are used to effectively clean
and maintain vehicles.   

Florida Chemical Company manufactures and markets a variety of
citrus by-products that are useful to companies manufacturing
products in these categories for sale in California.  The impact
of these standards would negatively impact automotive maintenance
personnel, classic automobile enthusiasts, and anyone who owns or
operates a motor vehicle in California.  Proper vehicle
maintenance is essential to maintaining the safety of automobiles
and the proper wear of automotive parts like brakes, carburetors,
engines, and others.   

Specifically, Florida Chemical is concerned that the ARB has not
considered the potential hazards that may be caused by residues on
automotive brake parts or other vital automotive parts.  We are
also concerned that the proposed standards will increase costs to
the automotive service industry and to consumers due to the
additional time required for brake jobs and other degreasing
operations from additional drying time and less effective
products.  Florida Chemical is also concerned that the ARB has not
considered benefits of effective engine maintenance in reducing
automotive VOC, nitrogen oxide, and particulate matter air
emissions.  In addition, the ARB has not considered the inability
to use low-vapor pressure (LVP) ingredients to reformulate these
products and the negative impacts of oily residues in air intake
systems that can collect soils from the air.  The ARB has also
failed to consider current limitations to carburetor or
fuel-injection air intake cleaner formulations due to the U.S.
EPA’s required registration of fuel additives.  Finally, Florida
Chemical is seriously concerned that these 10% VOC standards will
result in the essential elimination of these product categories
and the use of non-regulated solvents, like gasoline, in these
applications.  

Our industry has already reduced emissions from these products and
has offered to make additional reductions.  However the current
proposed 10% VOC standards are not a reasonable compromise, nor
are the proposed limits technologically and commercially feasible.
  Therefore we strongly suggest that the ARB withdraw the 10% VOC
standards and propose a more reasonable regulatory limit that will
protect California’s air quality without having such a severe
negative impact on these vitally important automotive maintenance
products.  


Sincerely,


Richard Pearl
Regulatory Affairs


cc: Andrew Hackman, ASPA
       D. Douglas Fratz, CSPA
       Joseph Yost, CSPA