2003 Consumer & Commercial Products Survey

FAQs

Updated: 9/27/2005

WHO MUST COMPLETE THIS SURVEY?

1. Is this survey mandatory?

2. We do not make consumer products.

3. If I didn't receive a survey, is it still mandatory for me to complete it?

4. Company Acquisition

5. Pet Products

6. Do I report my product if it is already reported annually to the Department of Pesticide Registration?

GENERAL QUESTIONS

1. Company Name Change

2. Customer Type

3. Multiple Companies

4. Coincidental Product Attributes

5. Exact Sales Information Not Available

6. Reporting Overfill

7. Industrial Products

8. General Purpose Degreasers (GPDs) And Multi-purpose Lubricants (MPLs)

9. Contract Employees

10. Webcast Training Session

11. Product Carried Portion Of Reporting Year

12. Label Revisions

13. Reporting Potpourri And Similar Products

ELECTRONIC VERSION

1. Why canít I type in some boxes?

2. Electronic Copies Of The Confidential Information Form

3. Difficulty Loading Database

4. Database Patch

5. Overnight Address Typo

6. Data Entry Forms Oversized

7. Reporting Sales Units For Wipes/Towels/Pads

8. "Blank Field" Error

INGREDIENT-RELATED QUESTIONS

WHO MUST COMPLETE THIS SURVEY?

1. Is this survey mandatory?

Question: Is completion of the survey mandatory under law?

Answer: Yes, completion of the survey is mandatory under California State Law. Responsible parties, formulators, and any other company holding data requested by the survey are required by law to report. On page II-2 of the survey (1st paragraph under "Background") is a reference to the California Health and Safety Code, along with our Consumer Products Regulation, that states that we have the authority to require the submission of information needed to carry out our duties.

2. We do not make consumer products.

Question: We do not make or otherwise deal with consumer products. Why did we get this survey and what do we need to do?

Answer: The survey was sent to a list of parties that are generally interested in regulations that affect consumer products. This list includes environmental groups, concerned citizens, government agencies, as well as many other types of businesses. If you are not listed on the label of a consumer product (see definition on page VII-21), then you are not considered a responsible party (definition on page I-2). Please send the Preliminary Form (page I-2) of the survey by fax or mail as indicated at the bottom of the form, indicating that you are not a responsible party for any product covered by the survey.

3. If I didnít receive a survey, is it still mandatory for me to complete it?

Question: Is completion of the survey mandatory for all "responsible parties" or only those who have received the survey?

Answer: Completion of the survey is mandatory for ALL responsible parties (see definition on page I-2 and authority references on page II-2). In fact, all responsible parties, formulators, and any other companies holding data requested by the survey are required by law to report. We make every effort to have a complete mailing list, but as you can imagine, it is quite difficult. If you provide us with the mailing address of anyone who should have received the survey, we will add them to our mailing list and send them a copy of the survey.

4. Company Acquisition

Question: Our company acquired another company that was the Responsible Party in 2003. We didn't own the products then; do we have to report the product?

Answer: Yes, you must report products that the company you acquired sold in 2003.

5. Pet Products

Question: We have products used for dogs and other animals, but no human/personal products. Do we have to complete this Survey?

Answer: Yes, as stated on page III-3 of the survey, pet products are being surveyed. The definition of pet care products can be found in the definition section on page VII-23. However, please note that only those pet care products that fall 2003 Survey categories must be reported during for this survey. All other pet care products (again, see pet care product definition) are planned to be surveyed next time, for Calendar Year 2005 sales.

6. Do I report my product if it is already reported annually to the Department of Pesticide Registration?

Question: Do I report my product if it is already reported annually to the Department of PesticideRegistration?

Answer: You should not report FIFRA registered products that require a license for possession or use. In addition, products that are used in accordance with the following definition of "Agricultural Use"
should not be reported.

"Agricultural Use" means the use of any pesticide or method or device for the control of pests in
connection with the commercial production, storage or processing of any animal or plant crop.
"Agricultural Use" does not include the sale or use of pesticides in properly labeled packages or
containers which are intended for: (A) Home use, (B) Use in structural pest control, or (C)
Industrial or Institutional use. For the purposes of this definition only: "Home use" means use in a
household or its immediate environment. "Structural pest control" means a use requiring a license
under Chapter 14 (commencing with Section 8500), Division 3, of the Business and Professions
Code. "Industrial use" means use for or in a manufacturing, mining, or chemical process or use in
the operation of factories, processing plants, and similar sites. "Institutional use" means use within
the lines of, or on property necessary for the operation of buildings such as hospitals, schools,
libraries, auditoriums, and office complexes.

"Agricultural Use" also includes any pesticide or method or device for the control of pests in
connection with nurseries, golf courses, parks, cemeteries, pastures, farms, forests, greenhouses
and right-of-ways.

Where animals are concerned, pesticides for domestic pets are consumer products, but pesticides
for livestock or other farm animals are agricultural products.

You may still have to report your FIFRA registered products if they fall into a survey category and
are available to household consumers. We have recently researched FIFRA registered products
and have found that many products under DPR jurisdiction can be purchased by household
consumers. These types of products may be subject to the ARB's Consumer Product's
Regulations. Please report any type of product that is available through any consumer outlet and
provide the FIFRA Registration number of the product in the comment field box on the bottom of
Form 3. If products are used exclusively at nurseries, golf courses, parks, cemeteries, pastures,
and/or right-of-ways and are not available to household consumers (see last sentence) then they
should not be reported. However if they are and can be used at sites other than the aforementioned
(excluding those qualifying under the "Agricultural Use" definition above) then they should be
reported. We intend to analyze FIFRA Registered products in consultation with the Department of Pesticide Regulation to ensure
that "double counting" of inventories does not occur.

GENERAL QUESTIONS

1. Company Name Change

Question: Our company was sold and the name changed. On the preliminary form, should we list our new company name or our name from the survey period (2003)?

Answer: Please use your new company name to submit the survey. To minimize confusion, please indicate the name change when sending in the Preliminary Form (page I-2). In addition, when submitting FORM 1, you can also indicate the name change in the FORM 1 comment field, under item 10.

2. Customer Type

Question: For the question on FORM 3, item 8, "Customer Type," may we list a percentage estimate? We would have a hard time figuring out the customer type who purchased the item.

Answer: The "Customer Type" question asks for the type of customer for which the product is intended. Typically, products are labeled and marketed to household, commercial, or industrial customers. Some products are also only available for purchase to certain customers. An estimate would be valid for this question, as long as your estimate is to the best of your knowledge.

3. Multiple Companies

Question: How do I complete the survey for multiple responsible parties? There are several companies owned by my "umbrella" company that meet your definition of "responsible party." Can I just put everything all together under one company name?

Answer: If you are submitting by hardcopy, one entire survey must be submitted per responsible party. If you are using the electronic version, you may enter data for multiple companies, however, a signed "FORM 1", and "Confidential Information Form" must be printed and submitted for each company.

4. Coincidental Product Attributes

Question: What if our product can serve the purpose of a category, but it is not labeled as such? How should we categorize this product? For example: Our products are labeled to "clean," but they often deodorize by chance. Additionally, they often have fragrance added only to minimize the chemical odors, but do not advertise their deodorizing properties on the label.

Answer: Choose the category according to the claims on the Principal Display Panel (see definition page VII-23) for the product. Coincidental attributes should not be considered when choosing a category.

5. Exact Sales Information Not Available

Question: My company is a responsible party, but we sell our product to various warehouse distributors throughout the nation. The products are then distributed from these locations as our customers see fit. Although I know that products are sent to California, the distributors will not provide the exact sales data for those products. How can I provide the sales data you require on FORM 3?

Answer: You can estimate the sales based on the assumption that a certain percent of the products were sent to California, based on population. See instructions on FORM 3, item 10: if California direct sales data are not available, sales may be estimated by prorating national, regional or distribution center figures by population. Attachment D on page V-17 of the survey, "U.S. Resident Population," has been provided to assist you with this estimation.

6. Reporting Overfill

Question: For the question on FORM 3, under item 12, what information should be used to determine if overfill is in excess of 2%? Should we simply compare the target value to the volume listed on the label?

Answer: Manufacturers often deliberately put more product into the container than listed on the label, so that the actual dispensed quantity matches the label. For example, if you put 8.3 oz of toothpaste into a tube, and there is 0.3 oz that won't come out because its stuck inside the tube, you may only list 8.0 oz on the label. This type of deliberate overfill (in excess of 2%) is the overfill we are referring to. We understand that actual variation due to the mechanical parts of the manufacturing processes is often quite minor, in addition to being overwhelming to record. With all this in mind, we ask for the average overfill in excess of 2%. In summary, compare your target/average filling data to the label. If you fill more than 2% over the amount stated on the label, please report that volume or mass as filled.

7. Industrial Products

Question: My product is sold only for use by Industrial facilities. Do we need to report "Industrial-use" products?

Answer: There is general misconception on the part of survey respondents that the term "industrial" means a product used in any capacity at an industrial or perhaps even a commercial facility. However, the term "Industrial Product" applies to very few products. For the purposes of the survey, industrial products include only those products that are incorporated into a finished, manufactured product or products used exclusively in the manufacture or construction of the finished item at that site. That is, the product is an integral necessary component to construct or manufacture the finished item. So, just because a product is used at industrial facilities, or even used exclusively at industrial facilities, it doesn't mean it fits the ARB definition of "industrial". Also, just because a product cannot be purchased by consumers for household use, doesn't mean it fits ARB's definition of "industrial" (see survey "industrial" definition, page VII-21). Finally, please note that all thinners, reducers, and aerosol adhesives, even those fitting our "Industrial" definition, need to be reported for the survey (see note on page III-3 of the survey packet).

For more information on the term "industrial" from a Regulatory perspective, the Air Resources Board's Enforcement Division has an advisory to more clearly describe the so-called "industrial" products that are not regulated under the California Air Resources Board (ARB) consumer products regulation (Title 17, California Code of Regulations (CCR), sections 94507-94517). You can view the advisory at the following web link: http://www.arb.ca.gov/enf/advs/advs307.pdf

8. General Purpose Degreasers (GPDs) And Multi-purpose Lubricants (MPLs)

Question: We have GPDs and MPLs which do not fit the survey's bolded definition because they are labeled "not for retail sale", and are also sold exclusively to establishments which manufacture or construct goods or commodities. Do we need to report these?

Answer: All GPDs and all MPLs need to be reported for the survey (these categories are listed on survey packet pages V-3 and V-5, respectively). In addition, GPDs and MPLs that are sold exclusively to establishments which manufacture or construct goods or commodies, and are labeled "not for retail sale", should be reported under the "other" categories (20399 and 21099), rather than under codes 20308 and 21004/5. This is because they do not fall under these category definitions. Over all, if you are unsure as to which category to place any of your GPD's or MPLs in, go ahead and report them under the "other" category (appears at end of the list), and ARB staff will sort it out.

9. Contract Employees

Question: How do I know which employees to include in question 9 on FORM 1? I donít understand the definition in the survey packet.

Answer: For this question, mark the range that is your best estimate of the number of people hired under contract, from an outside business or company. These are people working for your company that are not hired directly by your company; that is, people that work for your company that wouldn't be included in the previous question, #8. However, there is no need to scrutinize over your response on this question, just make your best estimate.

10. Webcast Training Session

Question: I was unable to participate in the December 3, 2004 survey webcast training session. Can I get a copy of the training?

Answer: We recorded the training session, and copies are available. Please contact Jessica Dean via email at jdean@arb.ca.gov to request a copy of the training video, which is available on DVD or CD (viewable via computer media players).

11. Product Carried Portion Of Reporting Year

Question: Do we report a product that we stopped carrying part way through 2003? What about products that we started selling for the first time at the end of 2003?

Answer: Any product falling under this survey that was sold during Calendar Year 2003, even at very small volumes, must be reported. The survey captures a "snapshot" in time. We are aware that products included may not have been sold over the entire reporting year. Keep in mind that we not only collect sales data, but also formula data, and any formula that was sold in 2003 is of interest to us.

12. Label Revisions

Question: We've had several label revisions since 2003. Which label do I submit?

Answer: Please submit the last label used in 2003 if possible. If you are unable to acquire that label, you can submit the most recent label, for example, the label you are currently using. However, if you submit a non-2003 label, please denote this in the comment field of FORM 3 for that product.

13. Reporting Potpourri And Similar Products

Question: How do I report the "Delivery/Packaging System", "Dispensed Form" and the "California Sales Data" on Form 3 for potpourri? (i.e. a fragrance applied to an organic substrate such as dried flowers, wood shavings, pine cones, etc.).

Answer: The reportable product in potpourri is the liquid portion applied to the organic substrate (just like in wipes or other impregnated delivery systems). The dried materials is considered part of the delivery system.

In reporting potpourri, select "other" and specify "potpourri" as the "Delivery/Packaging System" (FORM 3, item 5). For the dispensed form (FORM 3, item 6), select "liquid" for the liquid portion applied. In reporting the California sales data (FORM 3, item 12), estimate the amount of liquid fragrance (in fl oz) for each bag size of potpourri sold, and list this estimate in the "Product Size" column. Do not report the weight of the substrate; only report the liquid portion. For "Volume/Mass filled" column, simply list the same number you reported in the "product size" column. For clarification purposes, please note on the FORM 3 comment field the approximate sizes of the bags with substrate, and how, if necessary, you estimated the amount of liquid.

ELECTRONIC VERSION

1. Why canít I type in some boxes?

Question: Why wonít the electronic forms let me type information into some of the boxes?

Answer: Some of the boxes will only allow a certain number of characters, starting from the far-left side. It is easiest to use the "tab" key to move from one box to another while entering data. However, if you click into a box with your mouse, you must place it in the furthest left space of the box, or you won't be able to type all of the information. In addition, some entry fields are not "activated" until other information or fields have been completed.

2. Electronic Copies Of The Confidential Information Form

Question: On the electronic version, I can view the Confidentiality Information Form and Voluntary Survey Evaluation using the "Print Hardcopies" option, but the program wonít allow me to data enter these forms. Can I complete them electronically?

Answer: Because hard copies of these two forms must be mailed in, the electronic version of the survey will only allow you to print the form, not enter the data. Print the forms and complete them by hand and submit as described on page III-8 of the survey.

3. Difficulty Loading Database

Question: I'm having trouble installing the database onto my computer. Any suggestions?

Answer: The Microsoft Access runtime software that we have provided enables users to run the survey database whether or not they have Access loaded on their computer. However, there have been technical difficulties with the runtime software not loading properly with some versions of Windows. For some companies the Microsoft patch (see next question) fixed the problem.

A second option is to run the database using your own Access software, bypassing the Access runtime software. However, in order to use the database without loading the runtime software, you must have Microsoft Access already loaded on your computer (version 2000 or newer). Here are some general instructions for locating the database file on the provided CD and saving it to your computer directly; the names of your computer's drives or icons may vary. This process should work for both the Responsible Party (RP) and Formulator versions of the database, although the filenames provided below are for the RP version.

1) Create a folder on the drive where you will go to run the program (i.e. your computer's c-drive/ hard drive). You will be copying the program to this location on your computer, and running the database from this folder. Do not run the database from the CD directly.

2) Insert the survey CD into your drive and double-click the "My Computer" icon located on the desktop.

3) Double-click your "Compact Disc" drive to view the CD contents (look for the CD icon to recognize which is the CD drive).

4) Double-click the "2003 ARB Survey" folder.

5) Click on the zip file folder "consprodsurvey_2003.cab". This should activate Winzip (or similar software you have on your computer; see IT staff at your company if you need assistance "unzipping" this file).

6) Highlight the file called "consprodsurvey_2003.mdb" (should be the second to the last on the list) and click "extract".

7) Winzip will now give you an option of where to extract (or save) the file. Locate and select the folder created in Step 1, and click "extract".

8) After extraction, exit Winzip and your "Compact Disc" drive. Locate and open the folder (created in Step 1; where you extracted the database to in Step 6) to confirm that the "consprodsurvey_2003.mdb" file has been properly saved in this folder. You will need to return to this file to use the database. As you use the database, your information will be saved within this same database file.

Note: After you have entered all the survey data into the database, and double-checked your data, you can use the "export" feature located on the database "main menu" to save your data (in a compressed format) to a floppy disc or separate, writable CD, which will then be mailed to ARB. See the instructions located on the survey CD for more detail. If you have trouble using the export feature, as an alternative, you can just save the entire database file to disc (warning: this is a very large file).

If you have any questions about this process, or any problems loading or using the database, please contact Tina Najjar by phone at (916) 323-6501 or by e-mail at tnajjar@arb.ca.gov.

4. Database Patch

Question: While using the database, we couldn't switch between screens.

Answer: We have found a Microsoft database "patch" that may solve the problem, however, you should consult your IT staff before downloading any software or other information from the internet. The patch (Id# KB813617) is available at Microsoft's website, and is titled "Office XP Service Pack 3 (SP3) for Access 2002 Runtime" (ID# KB813617). Here is the weblink: http://www.microsoft.com/office/orkarchive/XPddl.htm.

If you have any problems loading or using the database, please contact Tina Najjar by email, at tnajjar@arb.ca.gov.

5. Overnight Address Typo

Question: On the coversheet for sending hardcopy FORM 4s to formulators, the "regular" and "overnight" mailing addresses are the same. Where do I send overnight packages?

Answer: For the overnight mailing address, use the following address as listed in the hardcopy:

California EPA Headquarters Building

Air Resources Board

1001 I Street (6th Floor)

Sacramento, CA 95814

Attn: SSD, Measures Development Section, 2003 Survey

6. Data Entry Forms Oversized

Question: The forms for entering are too large for the page; can I change the margins on the database?

Answer: As described at the bottom of the main menu screen, the database is best viewed as a screen resolution of 1024 X 768. If your monitor is at a different resolution, try adjusting the resolution, which may fix the problem. Instructions for adjusting the resolution are located under the "more info" button near the bottom of the main menu screen.

7. Reporting Sales Units For Wipes/Towels/Pads

Question: How do I indicate the "units" (i.e. wt oz, fl oz) for question 12 on FORM 3?

Answer: On the electronic version of the survey only, you will need to select either "Wipe-FO" for units of fluid ounces, or "Wipe-WO" for weight ounces.

8. "Blank Field" Error

Question: The database gives me an error message that I have a "blank field" and it wonít let me exit the form.

Answer: Go to the blank field blank field indicated in the error message and check if there is a blank line in the data. If there is, highlight the whole line by clicking to the far left of the line. Hit delete. It will then ask you if you want to delete the record. Click "yes".

INGREDIENT-RELATED QUESTIONS

1. Best Approach For FORM 4: Reporting Ingredients

Question: I'm having trouble understanding where to place ingredients on FORM 4. How should I approach FORM 4?

Answer: First, locate the entire formula (ingredients and weight percentages of each) for the product. When determining where to place your ingredients on Section C of Form 4, it should be helpful to think through the following process:

1) Are any chemicals in your product on the Specific Ingredient Table? If so, write the weight percent of the individual ingredients in the corresponding boxes.

2) Are any chemicals in your product considered fragrance? Use the definition of "fragrance" on page VII-20. Add the weight percent of all fragrances and write the total in the box "group all fragrance" at the bottom of the Speciation Table.

3) Are any chemicals considered inorganic? If the molecular formula of a chemical does not have any carbon in it, it is considered inorganic. Some inorganic chemicals are listed in the Specific Ingredient Table. For other inorganic chemicals, add their weight percents and write the total in the box labeled "group other inorganics" at the bottom of the Speciation Table.

4) Are any chemicals in your product considered exempt by ARB? Use the definition of "Volatile Organic Compound" (VOC) printed on page VII-25 of the survey packet. Chemicals that are exempt from being considered a VOC are listed in that definition. Some exempt chemicals are listed in the Specific Ingredient Table. For any other exempt chemicals, add their weight percents and write the total in the "group other exempts" box at the bottom of the Speciation Table.

5) Are any chemicals in your product listed in Attachment E? This attachment lists "Low Vapor Pressure Volatile Organic Compounds" (LVP-VOCs) that must be individually reported in the Speciation Table. If you see any of your ingredients on this list, fill in the Speciation Table with the chemical name, CAS number, and weight percent of each of those chemicals. If any of those ingredients are hydrocarbon solvents (such as "mineral spirits," "mixed hydrocarbons," or hydrocarbon blends), list also the trade name and manufacturer.

6) Are any chemicals in your product not listed in Attachment E considered LVP-VOCs? Use the definition of "Low Vapor Pressure Volatile Organic Compounds" (LVP-VOC) on page VII-22. For chemicals not listed in Attachment E that are LVP-VOCs, add their weight percentages and write the total in the box labeled "group other LVP-VOCs" at the bottom of the Speciation Table.

7) Whatís left? Remaining chemicals should be VOCs. List the chemical name, CAS number and weight percent of each of those chemicals in the Speciation Table. If any of them are hydrocarbon solvents, list also the trade name and manufacturer.

2. Chemical Properties

Question: I donít know any physical properties of a chemical. How do I know where to put it on FORM 4?

Answer: There are many resources you can use to determine the properties of the ingredient in question. The chemicalís Material Safety Data Sheet (MSDS) lists useful information, such as the chemical formula and the boiling point. Reference books, such as the Merck Index, CRC Handbook, and industry-specific ingredient guides also contain data you may find helpful in determining how to classify your ingredients. Several public, free web sites offer similar chemical data; see page III-11 for a list of some such sites. You may also seek help from your companyís research and development staff, quality check/quality assurance staff and/or other chemists within your company or formulating company. If, after exhausting your resources, you are still unsure where to report your ingredient on FORM 4, you can simply list it individually on the Speciation Table. We would rather have you err on the side of "reporting," rather than "grouping."

3. Products Without VOCs

Question: Most of the products we manufacture do not contain VOCs. Do we still have to report them?

Answer: Yes, to obtain complete and accurate information, any product falling under a category listed in the survey must to be reported, even zero-VOC products.

4. Which company should send FORM 4 (Ingredient Information)?

Question: We use a contract filler, or "formulator" according to the survey terminology, and our formulator would like to fill out FORM 4 and send it back to my company. Is it acceptable if my company sends it to you, instead of the formulator sending it directly to you?

Answer: Yes, the process of having the formulator send the information directly to the ARB was set up to protect any confidential ingredient information that the formulator has from the responsible parties that it fills for. It is not a problem if they choose to send that information to you; however, they should fill out the contact information at the bottom of the form in case any questions arise.

5. CAS (Chemical Abstract Service) List missing?

Question: A CAS List was provided in past surveys; why isn't it in the 2003 hardcopy survey packet?

Answer: We have provided the CAS List at the survey website, rather than in the hardcopy survey packet. We left it out to save paper, and also because we have been asked several times for it to be available in an electronic (searchable) format. Even so, we encourage individuals responding to the survey to obtain the CAS number from their supplier if possible, and not rely solely on our CAS List, which may be outdated. Refer to the language at the top of the list for more information.

6. VOC List

Question: Our company is currently developing a list of VOCs used in our products. Is there is a list of VOC's that we could use as a reference for this search? We currently stock over 6,000 chemicals and pulling the MSDS for each may be extremely time consuming.

Answer: Unfortunately, there are thousands of VOCs and the list continues to grow as new chemicals are developed. The only list we have available is the CAS list posted on the survey website, which is not composed exclusively of VOCs. As it is warned at the beginning of the list, the CAS List is not all-inclusive of the chemicals we are concerned with, VOC or otherwise. If you have a specific chemical that you need help with, let us know and we'll try to help. Generally, if there is some doubt about a compound, it may be easiest to list it individually on FORM 4 and let ARB staff sort it out when we review the submitted form.

7. BIN Numbers

Question: I called the supplier of my hydrocarbon solvent and they did not know what the bin number was; what is it and how can I find this number?

Answer: A bin number is a classification scheme that represents the overall photochemical reactivity of a group of solvents with similar characteristics. Although most of the large chemical suppliers are aware of bin numbers, you may encounter some that are unfamiliar with the term. Many suppliers do include the bin number on their product literature. Depending on the level of detail of the literature that accompanies shipments of the solvent, you may be able to determine the bin number without further consulting your supplier. For your convenience, we have compiled a list of some common hydrocarbon solvents and their bin numbers, as found in Attachment F. You can use Attachment G if your supplier cannot provide a bin number and your hydrocarbon solvent is not listed in Attachment F. The web site listed on page III-11 for reactivity can also give you more information about bin numbers.

Please note that bin numbers are required only for hydrocarbon solvents, not for VOCs or LVP-VOCs such as alcohols, glycol ethers, ketones, or acetates.

8. Formula Changes

Question: During the reporting year 2003, we had a formula change. Which formula should be reported?

Answer: A similar question is, "We now (in 2005) have a different formula than we did in 2003, what formula should we report?" In either case, report the last formula used for that product in 2003 (the latest formula used during Calendar Year 2003).

9. Multiple Formulators

Question: During the reporting year 2003, we had more than one formulator for our product. Which formulator should we ask to complete FORM 4, Ingredient Information?

Answer: Choose one "representative" formulator to submit ingredient information on behalf of your company; i.e. the formulator that you used most often.

10. Unable To Classify An Ingredient

Question: I am unable to determine if my ingredient is a VOC or LVP. I'm not sure where to include it on FORM 4. What should I do?

Answer: At any time you are unsure where to place and ingredient on FORM 4, go ahead and list it in the Speciation Table (Part C, Section 2) with the CAS # and weight percentage, and we will locate it appropriately when we review your forms. You can always contact survey staff for help as well.