Comment Log Display

BRIDGEVIEW AEROSOL, LLC
8407 South 77th Avenue
Bridgeview, IL 60455

Laboratory Phone: 708-237-4345
Laboratory Fax:   708-598-6513


November 1, 2006

Submit to:
dmallory@arb.ca.gov 
and via:
http://www.arb.ca.gov/lispub/comm/bcsubform.php?listname=cpwg2006&comm_period=A


David Mallory, P.E.
Manager, Measures Development Section, Stationary Source Division
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812

Re: Unreasonable 10% VOC Standards for Automotive Maintenance
Products

Dear Mr. Mallory:

Bridgeview Aerosol, LLC is very concerned about the Air Resources
Board’s (ARB’s) 10 % VOC emission standards for four automotive
maintenance product categories in the proposed 2006 Amendments to
California’s Consumer Products Regulation.  

The proposed 10% VOC standard for Brake Cleaners, Carburetor or
Fuel-Injection Air Intake Cleaners, Engine Degreasers, and General
Purpose Degreasers will destroy our ability to manufacture
automotive maintenance products that are used to effectively clean
and maintain vehicles.   

Bridgeview Aerosol, LLC is a private label aerosol producer that
manufactures products in all four of these categories for many
customers that market and sell these items in California.  The
impact of these standards would negatively impact these businesses
and their customers, i.e., automotive maintenance personnel,
classic automobile enthusiasts, and anyone who owns or operates a
motor vehicle in California.  Proper vehicle maintenance is
essential to maintaining the safety of automobiles and the proper
wear of automotive parts like brakes, carburetors, engines, and
other components provides for this safety.   

Specifically, Bridgeview Aerosol, LLC is concerned that the ARB
has not considered the potential hazards that may be caused by
residues on automotive brake parts or other vital automotive
parts.  We are also concerned that the proposed standards will
increase costs to the automotive service industry and to consumers
due to the additional time required for brake jobs and other
degreasing operations as a result of the additional drying time
required during cleaning and increased labor required because of
less effective products.  Bridgeview Aerosol, LLC is also
concerned that the ARB has not considered benefits of effective
engine maintenance in reducing automotive VOC, nitrogen oxide, and
particulate matter air emissions.  In addition, the ARB has not
considered the inappropriateness of low-vapor pressure (LVP)
ingredients used to reformulate these products and the negative
impacts that oily residues present in air intake systems where
soils from the air can build up and collect.  The ARB has also
failed to consider current limitations to carburetor cleaner
formulations due to the U.S. EPA’s required registration of fuel
additives.  Finally, Bridgeview Aerosol, LLC is seriously
concerned that these 10% VOC standards will result in the
elimination of these essential product categories and lead to the
use of non-regulated solvents, like gasoline, in these
applications.  As the effectiveness of the cleaning products
declines, end users will seek out other materials that will work
for them in these applications.

We have been a member of the CARB Technical Advisory Committee on
the IRTA study from its inception and we have continually voiced
our concern regarding the infeasibility of the formulations that
were regarded as “satisfactory” by IRTA.  Our internal
investigations of these products have not produced results that we
believed would lead to marketable products.  We had proposed that a
standard methodology be used to evaluate the formulations.  We have
shown in presentations to staff that the results obtained from that
methodology shows that the technical performance requirements were
not being met.  If the products do not meet performance
requirements, then they certainly cannot and will not be
commercially viable.

Our industry has reduced emissions from these products many times
and has offered to make additional reductions.  However the
current proposed 10% VOC standards are not a reasonable compromise
nor are the proposed limits technologically and commercially
feasible.   Therefore we strongly suggest that the ARB to withdraw
the 10% VOC standards and propose a more reasonable regulatory
limit that t will protect California’s air quality without having
such a severe negative impact on these vitally important
automotive maintenance products.  


Sincerely,

Edward S. Piszynski

Edward S. Piszynski
Vice President
Laboratory Services

cc: Andrew Hackman, ASPA
       D. Douglas Fratz, CSPA
       Joseph Yost, CSPA