Comment Log Display

JohnsonDiversey, Inc.
Global Headquarters
8310 16th St.
Sturtevant, WI 53177

Tel: 262 631 4001
																		 	


November 13, 2006
 
Clerk of the Board
Air Resources Board
1001 I Street, 23rd Floor
Sacramento, California  95814
 
Electronic submittal: 
http://www.arb.ca.gov/lispub/comm/bclist.php
 
Robert F. Sawyer, Ph.D, Chair
Air Resources Board
1001 I Street
Sacramento, California  95814
 
Subject:  Floor polish or wax VOC limits
 
Dear Dr. Sawyer:
 
Staff is proposing a 1% VOC limit for all floor polishes and waxes
which represents a major reduction from the current limits of 7%
VOC for flexible flooring and 10% VOC for non-resilient flooring. 
Johnson Diversey, Inc, is willing to accept the staff proposal for
the vast majority of floor polish/wax applications.  We however,
request that you direct staff to continue to work with us to
develop an appropriate mechanism to provide for specialized
commercial floor polishes at the 3% VOC level that, in use, will
emit no more VOCs than products meeting the 1% staff proposed
limit.  These very specialized products last at least three times
longer between applications than a typical 1% VOC product.

About JohnsonDiversey, Inc.

JohnsonDiversey (JD) is a  market leader in the floor wax/polish
category, representing twenty percent of the market, predominantly
in the premiere performance product market.  JD is larger than the
next eight companies combined in floor polish/wax products.  No
other company has the prominence, expertise and knowledge that JD
has in this product category and we view ourselves as the cutting
edge/quality leader.  An enormous amount of research and
development goes into creating these products.  We are also deeply
committed to environmental sustainability as reflected by our
corporate heritage and our industry leading Healthy High
Performance Cleaning program, participation in the US Green
Building Council’s green building program, LEED, green product
certifications with Green Seal, and many others. 

JohnsonDiversey has Worked with Staff on a 3% Subcategory

JD understands and appreciates the challenge faced by the ARB and
the need for emission reductions from any and all possible
sources.  However, we strongly believe that products specifically
designed to require burnishing as part of prescribed and required
maintenance are deserving of a subcategory within the resilient
floor polish/wax category.  In communications with ARB Staff, we
have defined this category of floor polishes, specifically
designed to require burnishing as part of prescribed and required
maintenance, as the ‘must burnish’ products.  Burnishing resilient
floor polish/wax products is recognized as a common industry
practice for these products in order to extend service life
between product reapplication.  From an emissions perspective, the
justification for this 3% VOC subdivision is specifically designed
performance characteristics that make “must-burnish” products last
at least three times longer between applications when compared to
1% VOC products that do not respond to burnishing.

We have worked extensively with Staff to develop a 3% subcategory
for this group of products.  JD remains convinced that products,
which average about 3% VOC, meet very specific needs in the
marketplace for maintaining acceptable appearance, adequate
flooring protection, and minimizing business interruption through
reduced reapplication requirements while maintaining a safe
surface for the public to walk on.  These characteristics are
especially critical in healthcare, hospitality, retail and
government facilities which tend to be “24 hour” in open
operation. Application of floor finishes requires multiple coats
to be applied with time to dry between coats, disrupting business
activity in that area of the facility. The application process is
also very labor intensive. Loss of these extended service life
“must-burnish” products from the marketplace would have a negative
economic impact on these businesses and government facilities
through increased labor costs and business interruption.
 
Once applied, these products only need periodic burnishing with a
high speed mechanical buffing machine to repair and restore the
existing floor polish appearance.  Further, we also believe that
in-use emissions from usage of these ‘must burnish’ 3% VOC
products will be no greater and likely less than in-use emissions
from 1% VOC products.  This is because of the reduced number of
applications of product and the reduction in the use of VOC
containing chemical strippers used to remove existing finishes
before installations.
 
We also want to note that even with a 3% subcategory, JD will need
to reformulate a significant number of products and likely will
incur expense of millions of dollars. Without the subcategory, the
expense is not expected to be significantly higher. 


We believe staff understands industry’s assertions that a 3%
sub-category has merit and we also believe that staff has worked
with us to try to develop the appropriate definitive criteria for
such a sub-category.   Unfortunately, we have, to date, been
unsuccessful in our quest.
 
Conclusion

Due to our inability to date to identify an enforceable set of
defining criteria for the subcategory, and faced with a tight time
frame, JD will not oppose the current staff proposal of a 1% VOC
limit across the product category.  We also commit to
investigating with staff all other possible options for compliance
including the Innovative Product Exemption and the Alternative
Compliance Plan available under current ARB regulation.  Finally,
we respectfully request that the Board and staff be willing to
revisit the creation of a subcategory in the future if an adequate
definition can be developed.
 
JD would again like to acknowledge the willingness of your staff
to work with us on this issue.  They have granted us every meeting
we requested and have been professional through each step of the
process.  Staff has indicated their continued willingness to work
with us on this issue and all the compliance options available. JD
has already devoted considerable resources evaluating the
feasibility of a 1% VOC limit and the effort required for
reformulation of their floor wax/polish products and will continue
our focus in this area in light of these regulations.
 
Sincerely,
 
  

Robert J. Israel, Ph.D.
Director, Corporate Product Responsibility
 
 
cc:  Honorable Members, Air Resources Board