Comment Log Display

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/