First Name | Kenneth E. |
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Last Name | Forbes |
Email Address | keforbes@ashland.com |
Affiliation | Ashland Inc. Fairfield, CA |
Subject | VOC Reduction in Consumer Products-Automotive Cleaners |
Comment | October 27, 2006 Attention: State of California, Air Resources Board (ARB), Please DO NOT amend the present limits of VOC in consumer products used in the automotive industry, specifically brake cleaners, engine degreasers and general degreaser and carburetor and fuel injection cleaners. These proposed amendments fail to fully consider the long-term safety aspect related to reformulation. A thorough, controlled study of the efficacy of the proposed reformulations has yet to be completed. The data obtained on the alternative automotive cleaners used in the 2005 IRTA Wolf study primarily employed soy oil/acetone blends, Simple Green and water based blends. The study itself appears to be cursory, incomplete and uncontrolled. For example, how much effort was used in each location, with each cleaner, to exact a degree of cleanliness? How "clean" was "clean" in the cleaning descriptions, which appear to be somewhat subjective? Were there controls for each cleaning situation? Was it a double-blind study? How much residue was left in each "cleaning" compared to solvents in use now? Were cleaners with other VOC-exempt compounds such as PCBTF and Methyl Acetate looked at? If not, then why not? These are also effective non-VOC solvents that were not used with soy oil in the study. These questions do not appear to be answered in this study. They should be answered prior to any VOC content amendments for automotive consumer products. To remove effective cleaners for safety-sensitive equipment used on California roadways without fully studying the safety and reliability aspect in an effort to achieve a relatively minor reduction in VOC emissions is unwise, unacceptable to those who presently formulate safe and highly-effective cleaners, and not in the best interests of Californians who depend on the quality products from respected manufacturers like Valvoline and Aervoe Industries, who have already reduced VOCs on these products one before. More study is clearly needed with a more detailed look into safety, efficacy and a true cost-benefit analysis. I respectfully ask you to seriously consider these comments and questions related to proposed major changes that ARB would mandate in the VOC content of automotive consumer products. Our vehicle assets, performance and most of all, our safety are at stake here. Thank you, Ken Forbes Analytical Chemist Quality Assurance Laboratory Ashland Distribution Division of Ashland Inc. 2461 Crocker Circle Fairfield, CA 94533 707-437-4000 x 607 keforbes@ashland.com http://www.cspa.org/keepcarsrolling/ |
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Date and Time Comment Was Submitted | 2006-10-27 17:17:42 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.