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Comment 76 for Consumer Products (cpwg2006) - 45 Day.

First NameBruce
Last NameDouglass
Email Addressbruce@fastundercar.com
AffiliationFast Undercar
SubjectProposed 10% VOC standard for Brake Cleaners
Comment
Fast Undercar and its customers are very concerned about the VOC
emission standards for four automotive maintenance product
categories in the proposed CONS-2 regulation.  

The proposed 10% VOC standard for Brake Cleaners, Carburetor or
Fuel-Injection Air Intake Cleaners, Engine Degreasers, and General
Purpose Degreasers could have a negative impact on consumers from
increase costs since less effective products will require more
time for routine auto maintenance.  We are also concerned that ARB
has not fully considered the impact of these standards and has not
conducted significant long-term testing to ensure that the
resulting products will not endanger vehicle safety or consumer
preferences.  

We understand that the automotive product industry has already
reduced emissions from these products and has offered to make
additional reductions.  We are asking ARB to reconsider its 10%
VOC standards and consider a compromise that will protect
California’s air quality without having a negative impact on our
members’ ability to provide quality vehicle maintenance.  

Sincerely,
Bruce Douglass, President and CEO

Attachment
Original File Name
Date and Time Comment Was Submitted 2006-11-14 08:45:46

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