Consumer Products and Smog

Ozone, the main ingredient of smog, continues to threaten the health of many Californians. Although the state's air is the cleanest in over 30 years, most Californians still live in areas where smog reaches unhealthy levels. Reducing air pollution from cars and businesses hasn't been enough. To meet state and federal air quality standards, many small sources also need to pollute less. This includes consumer products.  To achieve these goals, the California Air Resources Board (ARB) mandates limitations and/or restrictions on certain types of chemicals that cause pollution and have harmful heatlh effects in consumer products.  This information is published in The California Consumer Products Regulations.

Consumer Product Pollution Adds Up

Deodorants, hair spray, cleaning products, spray paint, and insecticides are examples of common consumer products that are made with ozone-forming chemicals known as volatile organic compounds or VOCs. Although each product only contains a small amount of VOCs, Californians use over half a billion of these items every year.  VOCs are an important precursor, or component in the formation of ground level ozone, a major part of California's smog problem.  By regulating the amount of VOCs in consumer products, ARB is helping to reduce smog and reduce public exposure to the hazards associated with smog.

In 2010, consumer products are projected to account for about 250 tons per day (tpd) of VOC emissions, which is about 12 percent of the total VOC emissions statewide. If consumer products had never been regulated, we calculate emissions would have exceeded 450 tons per day by 2010. Thus, ARB's efforts have already resulted in projected emissions reductions of over 48% when the regulations are fully in effect. Even though these significant reductions have been achieved, population growth will erode some of these reductions such that consumer product emissions are projected to increase unless more is done.

The Law Requires Cleaner Products

State and Federal law require that consumer products pollute less. To achieve this, the ARB works with industry and other stakeholders to develop requirements that achieve the maximum feasible VOC emission reduction while making sure that the regulations are technologically and commercially feasible and do not eliminate a product form. Today, standards that reduce VOCs have been established for over 100 categories, but further reductions are still needed.

On September 25, 2007, the ARB adopted the Proposed 2007 State and Federal Strategy for the California State Implementation Plan (SIP), which reaffirms the ARB's commitment to achieve the health-based air quality standards through specific near-term actions and the development of additional longer-term strategies. It also sets into motion a concurrent initiative to identify longer-term solutions to achieve the full scope of emission reductions needed to meet federal air quality standards in the South Coast and San Joaquin Valley by 2010. These strategies address meeting the federal one-hour ozone standard.

On June 15, 2004, however, the new eight-hour ozone standards became effective, causing a transition from the one-hour ozone standard, 0.12 parts per million (ppm), to the more health-protective eight-hour ozone standard, 0.08 ppm (averaged over 8 hours). Strategies to meet this new standard were adopted on September 25, 2007.  ARB expects that California will need to reduce emissions beyond the existing commitments.

Many of the emissions reductions will need to come from the areas of California with the highest population and the worst smog problems.  South Coast houses about 43% of all California residents, and the San Joaquin Valley is home to a vast area of California's rich agriculture.  These valleys have the worst air quality in California and therefore require further regulation on sources of air pollution that create their smog problem, and this includes further regulations on consumer products in order to meet California's commitment to the SIP.  

Commercial and Technological Feasibility

The California Clean Air Act requires that the ARB assure that each new consumer product regulation is commercially and technologically feasible and does not eliminate a product form. To evaluate feasibility, the Consumer Products Program staff conducts surveys to be completed by manufacturers that sell products in California. The purpose of these surveys is to gather current information on VOC emissions from consumer and commercial product categories. This information allows us to determine the feasibility of further reducing consumer product emissions and is used to update our consumer products emission inventory.

Toxics

The ARB is also committed to reducing exposure to toxic compounds used in consumer products. To that end, the use of the Toxic Air Contaminants (TAC) perchloroethylene (perc), methylene chloride (mecl), and trichloroethylene (tce), has been prohibited from use in the following categories because these compounds are potential carcinogens:

ARB has also approved an Air Toxics Control Measure (ATCM) that prohibits the use of the potential human carcinogen para-dichlorobenzene (PDCB), which has been used in air fresheners and in toilet/urinal deodorant blocks.

Reactivity

Reactivity is the ozone-forming potential of a particular VOC. Reactivity limits were developed for aerosol coatings based on the maximum incremental reactivity (MIR) scale. This approach increases flexibility for the regulated industries. The ARB is continuing to evaluate development of more reactivity limits for other categories on a case-by-case basis. However, achieving mass-based VOC reductions will continue to be our primary approach.

Flexibility for Cost-Effective Solutions

The average cost of reducing pollution from consumer products is comparable to other VOC regulations-about 25 to 85 cents for every pound of VOC emissions prevented. California's consumer product regulations give manufacturers the flexibility to find the most cost-effective approach.

Performance Standards set allowable VOC content for a product category. Companies can choose how to modify their product formulas to reduce VOC content.

Innovative Products Provision allows manufacturers to exceed performance standard VOC limits if they can demonstrate alternative ways of lowering emissions. For instance, increasing the amount of "active ingredients" and changing the dispenser can lower the amount of VOC emitted per application.

Alternative Control Plan allows manufacturers to average, or "bubble," their emissions from noncomplying products with those from products that more than meet the standard. The resulting emissions average must be less than or equal to the emissions that would result had all the products met the standards.

Variances provide temporary relief from the VOC limits in the consumer product regulation. A company must demonstrate in a public hearing that they cannot comply for reasons beyond their control.