Comment Log Display

November 13, 2006


California Air Resources Board
Headquarters Building
1001 "I" Street
P.O. Box 2815 
Sacramento, CA  95812 

RE: Support for Proposed Amendments to the Consumer Products
Regulation and the Aerosol Coatings Regulation


Community Action to Fight Asthma (CAFA), a statewide network of
asthma coalitions working to reduce environmental triggers of
asthma for school aged children, urges the California Air
Resources Board to support amendments to the Consumer Products
Regulation and the Aerosol Coatings Regulation.  These amendments
will set forth new Volatile Organic Compound (VOC) limits which
will achieve a 10.6 tons per day VOC emission reduction statewide
by 2008 and an 11.5 tons per day reduction by 2010.  These
reductions will result in continued progress in achieving state
and federal ambient air quality standards and improving health for
California residents.

One of CAFAs priorities is to improve indoor air quality since
adults and children, on average, spend 90% of their time during
the week indoors.  The majority of this time is spent in the home
where individuals can be exposed to many uncontrolled
environmental triggers, including VOCs, which can cause irritation
to the lungs and can lead to asthma, allergies and other health
threatening conditions.  Children also spend much of their day in
school classrooms, which can impose additional exposure to indoor
air pollutants.  Current reports indicate that one in ten
school-age children suffer from asthma symptoms.

Recent studies throughout California found there were high air
concentrations of formaldehyde and VOCs in some traditional and
portable school classrooms due to various indoor sources and/or
poor ventilation.  VOCs are respiratory irritants emitted into the
air by building and interior finish materials, furnishings, and
cleaning and teaching products.  These indoor air pollutants can
trigger asthma attacks and have an effect on student and staff
health, academic achievement, and absenteeism.  Identifying these
triggers and working to eliminate them can help reduce the
frequency and intensity of asthma attacks and provide a healthier
learning environment for students and staff.

Of the many asthma triggers in the environment, air pollution is
one of the few that can be influenced by policies and regulations.
 The Amendments to the Consumer Products Regulation and the Aerosol
Coatings Regulation would achieve VOC emission reductions overall,
which would have an impact on improving indoor air quality and
reducing asthma triggers.  These improvements directly impact the
health of many who work to manage their asthma on a daily basis.  


Asthma coalitions throughout the state, as part of the CAFA
Network, are working to improve both indoor and outdoor air
quality. In some communities, for example, coalitions are working
to implement and enforce indoor and outdoor air quality asthma
policies and programs in schools while others are building
awareness of air quality problems through inventive community
collaborations and partnerships.  Regardless of the particular
approach, however, coalitions recognize that they can’t fix the
air quality problem on their own, and that appropriate regulations
must be in place to protect the public’s health – particularly the
health of children.  Amendments to the Consumer Products
Regulation and the Aerosol Coatings Regulation will go a long way
to providing much needed assistance to working toward a solution.

Thank you for your time and consideration.  Please feel free to
contact me at 510-302-3316 with any questions or concerns.

Sincerely,



Joel Ervice
Associate Director 
Regional Asthma Management and Prevention (RAMP) Initiative
Statewide Coordinator of Community Action to Fight Asthma (CAFA)