| First Name | Sara |
|---|---|
| Last Name | Seidl |
| Email Address | sara.seidl@ecolab.com |
| Affiliation | Ecolab, Inc. |
| Subject | Ecolab Comments to Proposed Amednments to the Consumer Products Regulations |
| Comment | September 23, 2013
Clerk of the Board
California Air Resources Board
1001 I Street
Sacramento, CA 95912
via web portal - http://www.arb.ca.gov/lispub/comm/bclist.php
Subject: Proposed Amendments to the Consumer Products Regulations
Dear Clerk of the Board,
Ecolab appreciates the opportunity to comment on the amendments to
the Consumer Products regulation. These amendments are to be heard
by the California Air Resources Board on September 26, 2013.
A trusted partner at more than one million customer locations,
Ecolab (ECL) is a global leader in water, hygiene and energy
technologies and services that protect people and vital resources.
With 41,000 associates, Ecolab delivers comprehensive solutions and
on-site service to help ensure safe food, maintain clean
environments, optimize water and energy use and improve operational
efficiencies for customers in the food, healthcare, energy,
hospitality and industrial markets in more than 170 countries
around the world.
Ecolab has the following comments.
• Ecolab supports the addition of the definitions for Single
Purpose Cleaner and Single Purpose Degreaser. Ecolab produces
General Purpose products and Single purpose products. The addition
of the definitions provides clarity to the regulation.
• Ecolab supports the scientific pathway being taken by the staff
in dealing with the Low Vapor Pressure (LVP) provision. LVP
compounds are extremely important in maintaining compliance with
current and future VOC limits. The LVP provision is needed to
provide technical feasibility to the current VOC limits.
In summary, Ecolab supports the amendments to the Consumer Product
regulation.
Thank you for your consideration to these comments. Any questions
or comments feel free to call our consultant Doug Raymond at
440-474-4999 or at djraymond@reg-resources.com.
Sincerely,
Sara Seidl
ASSOCIATE REGULATORY SPECIALIST I, LoG, CFIA, VOC
ECOLAB 370 WABASHA STREET NORTH, ST. PAUL, MN 55102
T 651 293 4292 F 651 225 3122 E Sara.Seidl@ecolab.com
Cc: Carla Takemoto, Air Resources Board
Doug Raymond, Raymond Regulatory Resources (3R), LLC
|
| Attachment | www.arb.ca.gov/lists/com-attach/9-cp2013-AWRWM1U7AzxXMANh.pdf |
| Original File Name | Ecolab Comments to Proposed Amendments to the CARB Consumer Products Regulations September 2013.pdf |
| Date and Time Comment Was Submitted | 2013-09-23 09:27:20 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.